PRIVACY POLICY

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Data Controller

Francesco De Robertis

Via Martiri di Cefalonia 26, 63822, Porto San Giorgio (FM), Italy
VAT number: 02426590440

Owner's email address: francesco.derobertis@we-together.it

Types of Data collected

Among the Personal Data collected by this site, independently or through third parties, there are: email; First name; Surname; Cookies; Usage data; various types of Data; Data communicated while using the service.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this website.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory are encouraged to contact the Owner.
Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

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Method and place of processing of the collected Data

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Methods of treatment

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

• the User has given consent for one or more specific purposes; 

• the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;

• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

• the treatment is necessary for the execution of a task of public interest or for the exercise of public powers with which the Data Controller is invested;

• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

In case of superior protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the contact details indicated at the beginning.

Storage period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.

• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the treatment is based on the User's consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the processing of the collected data

The User's Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any malicious activity or fraudulent, as well as for the following purposes: Contacting the User, Statistics, Interaction with social networks and external platforms, Managing contacts and sending messages, Interaction with platforms for online surveys, Viewing content from external platforms, Tag management, Registration and authentication, Platform services and hosting, Advertising, Remarketing and behavioral targeting, Content commenting, Interaction with live chat platforms, Heat mapping and session recording, Management of data collection and online surveys, Access to accounts on third party services , Interaction with data collection platforms and other third parties, Traffic optimization and distribution e Content and functionality performance testing (A/B testing).

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.

Facebook permissions requested by this Application

This Application may ask for some Facebook permissions which allow it to perform actions with the User's Facebook account and to collect information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information on the permissions below, please refer to Facebook permissions documentation ed to Facebook privacy policy.

The permissions required are as follows:

Basic information

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and localization language and, in some cases, the "Friends" of Facebook. If the User has made additional Data publicly available, the same will be available.

Access to activities

Provides access to the User's activity list.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Access to accounts on third party services

  This type of service allows this Application to collect Data from your accounts on third-party services and perform actions with them.
  These services are not activated automatically, but require the express authorization of the User.

• Content commenting

  The comment services allow Users to formulate and publish their own comments regarding the content of this Application.
  Depending on the settings decided by the Owner, Users can also leave comments anonymously. If there is an email among the Personal Data released by the User, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
  In the event that a comment service provided by third parties is installed, it is possible that, even if the Users do not use the comment service, the same collects traffic data relating to the pages in which the comment service is installed .

  Facebook Comments (Facebook, Inc.)

  Facebook Comments is a service managed by Facebook, Inc. which allows the User to leave comments and share them within the Facebook platform.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy.

• Contact the user

  Mailing list or newsletter (this Application)

  By registering with the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application may be sent. The User's email address could also be added to this list as a result of registering with this Application or after making a purchase.

  Personal Data processed: surname; e-mail; first name.

  Contact form (this Application)

  By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the header of the form.

  Personal Data processed: surname; e-mail; first name.

• Contact management and sending messages

  This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
  These services could also allow the collection of data relating to the date and time of viewing of messages by the User, as well as the User's interaction with them, such as information on clicks on the links inserted in the messages.

  Mailchimp (The Rocket Science Group LLC.)

  Mailchimp is an address management and email message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: surname; e-mail; name;phone number.

  Place of processing: United States – Privacy Policy.

• Tag management

  This type of service is functional for the centralized management of the tags or scripts used on this Application.
  The use of these services involves the flow of User Data through them and, where appropriate, their retention.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Usage data.

  Place of processing: Ireland – Privacy Policy.

• Management of data collection and online surveys

  This type of service allows this Application to manage the creation, implementation, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse the Data of the responding Users.
  The Personal Data collected depends on the information requested and provided by the Users in the corresponding online form.

  These services can be integrated with a wide range of third-party services to allow the Owner to perform subsequent actions with the processed Data - for example, contact management, sending messages, statistics, advertising and payment processing.

  Advertisements for Facebook lead acquisition (Facebook, Inc.)

  Facebook Lead Ads is an advertising and data collection service provided by Facebook, Inc. that allows users to display advertisements in the form of forms that are pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be asked to provide additional information.

  Submitting the form involves the collection and processing of these Data by the Data Controller in accordance with this privacy policy and only for the specific purpose indicated in the form and/or within this privacy policy, where provided.

  The User can exercise his rights at any time, including the right to withdraw consent to the processing of his Data, as specified in the section containing information on the User's rights in this privacy policy.

• Hosting and backend infrastructure

  This type of service has the function of hosting Data and files that allow this Application to function, allow its distribution and provide a ready-to-use infrastructure to deliver specific functions of this Application.
  Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

  Wix.com (Wix.com LTD.)

  Wix  is a hosting service provided by Wix.com LTD.

  Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Israel -Privacy Policy

• Interaction with live chat platforms

  This type of service allows you to interact with live chat platforms, managed by third parties, directly from the pages of this site. This allows the User to contact the support service of this site or for this site to contact the User while he is browsing its pages.
  In the event that an interaction service with live chat platforms is installed, it is possible that, even if the Users do not use the service, the same collects Usage Data relating to the pages in which it is installed. Also, live chat conversations may be recorded.

  Wix Chat (Wix.com LTD)
  Wix Chat is an interaction service with the Wix live chat platform, provided by Wix LTD
  Personal Data processed: Cookies; Data communicated while using the service; Usage data.
  Place of processing: Israel – Privacy Policy.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
  In the event that one of these services is installed, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed.

• Interaction with social networks and external platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of this site.
  The interactions and information acquired from this site are in any case subject to the User's privacy settings relating to each social network.
  This type of service could still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out of the respective services to ensure that the data processed on this Application is not reconnected to the User's profile.

  LinkedIn button and LinkedIn social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network, provided by LinkedIn Corporation.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook "Like" button and social widgets are services allowing interaction with the Facebook social network, provided by Facebook, Inc.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy.
  Instagram button and social widgets (Facebook, Inc.)
  The Instagram button and social widgets are services allowing interaction with the Instagram social network, provided by Facebook, Inc.
  Personal Data processed: Cookies; Usage data.
  Place of processing: United States – Privacy Policy.
  YouTube button and social widgets (Google LLC.)
  The YouTube button and social widgets are interaction services with the YouTube social network, provided by Google LLC.
  Personal Data processed: Cookies; Usage data.
  Place of processing: United States – Privacy Policy.

• Traffic optimization and distribution

  This type of service allows this Application to distribute its content through servers located throughout the territory and to optimize its performance.
  The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter communications between this Application and the User's browser.
  Given the distributed nature of this system, it is difficult to determine where content is transferred, which may contain the User's Personal Data.

• Advertising

  This type of service allows the User's Data to be used for commercial communication purposes. These communications are shown on this site in the form of banners and other forms of advertising, also in relation to the interests of the User.
  This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.
  Some of the services listed below may use Cookies or other Identifiers to identify Users or they may use the behavioral retargeting technique, i.e. displaying personalized advertisements based on the User's interests and behaviour, including those detected outside this Application. For more information on this, we suggest you check the privacy policies of the respective services.
  In addition to the opt-out features offered by the services listed below, the User can opt-out by visiting the opt-out page of the Network Advertising Initiative.

  Users may also choose not to participate in certain advertising features through the corresponding device configuration options, such as the mobile device advertising configuration options or the generic advertising configuration.

  Facebook Lookalike Audience (Facebook, Inc.)

  Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook's Custom Audience service in order to show advertisements to Users with similar behaviors to Users who are already in a list Custom Audiences based on their previous use of this Application or their interaction with relevant content across Facebook applications and services.
  Based on this Data, personalized ads will be shown to Users suggested by Facebook's Lookalike Audience.

  Users can choose not to use Facebook cookies for ad personalization by visiting this opt-out page.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy 

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook's use of data, please see Facebook's data policy.

  To allow the functioning of Facebook Audience Network, this Application can use some identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for OS) or technologies similar to cookies. Among the ways in which Audience Network proposes advertising messages to the User, there is also the use of the latter's advertising preferences. The User can control the sharing of his advertising preferences within the Facebook Ad settings.

  You can opt-out of some Audience Network targeting features through your device settings. For example, it can change the advertising settings available for mobile devices.

  Personal Data processed: Cookies; Usage data; unique device identifiers for advertising (Google Advertiser ID for example).

  Place of processing: United States – Privacy Policy – Opt out.

  Google AdSense (Google Ireland Limited)

  Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the "DoubleClick" Cookie, which traces the use of this Application and User behavior in relation to advertisements, products and services offered.

• Remarketing and behavioral targeting

  This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the past use of this Application by the User.
  This activity is facilitated by the tracking of Usage Data and by the use of Tracking Tools to collect information which is then transferred to the partners who manage the remarketing and behavioral targeting activities.
  Some services offer a remarketing option based on email address lists.
  Users may also choose not to participate in certain advertising features through the corresponding device configuration options, such as the mobile device advertising configuration options or the generic advertising configuration.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

  Users can choose not to use Facebook cookies for ad personalization by visiting this opt-out page.

  Personal Data processed: Cookies; e-mail.

  Place of processing: United States – Privacy Policy – Opt out.

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. which connects the activity of this Application with the Facebook advertising network.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy – Opt out.

• Platform services and hosting

  These services are intended to host and operate key components of this Application, making it possible to deliver this Application from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for electronic commerce, for processing payments, etc. The use of these tools involves the collection and processing of Personal Data.
  Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

  Wix.com (Wix LTD)

  Wix.com is a platform provided by Wix LTD which allows the Owner to develop, operate and host this site.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Israel – Privacy Policy.

• Statistics

  The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour.

  Google Analytics

  Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
  Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy.

  Wix Analytics Reports (Wix LTD)

  Wix Analytics Reports is a statistics service provided by Wix LTD.

  Personal Data processed: Cookies; Usage data.

  Place of processing: Israel – Privacy Policy.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

  Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed within this Application. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram and Audience Network ads.

  Personal Data processed: Cookies; Usage data.

  Place of processing: United States – Privacy Policy.

  Facebook Analytics for Apps (Facebook, Inc.)

  Facebook Analytics for Apps is a statistics service provided by Facebook, Inc.

  Personal Data processed: Usage data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Content and functionality performance testing (A/B testing)

  The services contained in this section allow the Data Controller to track and analyze the response from the User, in terms of traffic or behaviour, in relation to changes to the structure, text or any other component of this Application.

  Google Optimize (Google Ireland Limited)

  Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").

  Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Usage data; Tracking Tool.

  Place of processing: Ireland – Privacy Policy.

  Google Optimize 360 (Google Ireland Limited)

  Google Optimize 360 is an A/B testing service provided by Google Ireland Limited ("Google").

  This service allows the Owner to target groups of Users based on their past use of this Application. Users who they disable tracking by Google Analytics will not be included in experiments created within Google Optimize 360.

  Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Usage data; Tracking Tool.

  Place of processing: Ireland – Privacy Policy.

• Viewing content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them.
  This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a font style visualization service managed by Google Ireland Limited that allows this Application to integrate such content within its pages.

  Personal Data processed: Usage data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

User rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In case of superior protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out which rights are applicable in his case and how to exercise them.

In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data.

• oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.

• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

• check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.

• obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.

• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.

• receive their data or have them transferred to another owner. The User has the right to receive his Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.

• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

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Cookie Policy

This Application uses Trackers. To find out more, the User can consult the Cookie Policy.

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Learn more about treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this site or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

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Specific information

At the request of the User, in addition to the information contained in this privacy policy, this site could provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

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System and maintenance logs

For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User's IP address.

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Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

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Response to “Do Not Track” requests

This Application does not support “Do Not Track” requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

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Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this site as well as, if technically and legally feasible, by sending a notification to Users via one of the contact you have. Therefore, please consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

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Definitions and legal references

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Personal Data (or Data)

Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

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Usage Data

This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.

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User

The individual who uses this Application who, unless otherwise specified, coincides with the interested party.

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Interested

The natural person to whom the Personal Data refer.

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Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, according to what is set out in this privacy policy.

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Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures relating to the functioning and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

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This site

The hardware or software tool through which the Personal Data of Users are collected and processed.

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Service

The Service provided by this Application as described in the relative terms (if available) and on this site/application.

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European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

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Cookies

Cookies are Tracking Tools that consist of small portions of data stored in the User's browser.

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Tracking Tool

Tracker means any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – which allows tracking Users, for example by collecting or saving information on the User's device.

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Legal references

This privacy statement has been prepared on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement applies exclusively to this site.

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