Privacy Policy

This Website collects some Personal Data from its Users.

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Data Controller

Daniele Papa

Controller email address:

cledupalermo@gmail.com

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: Tracking Tool; Usage Data; email; first name; last name; date of birth; phone number.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to the collection of the data itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.

Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to communicate it, it may be impossible for this Website 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 its operation.

Users who have doubts about which Data is mandatory are encouraged to contact the Controller.

Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the 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 Website and guarantees to have the right to communicate or disseminate them, releasing the Controller from any liability toward third parties.

Mode and place of processing the collected Data

Methods of processing

The Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

The processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Controller. The updated list of these parties may be requested from the Data Controller at any time.

Legal basis of processing

The Controller may process Personal Data relating to Users if one of the following conditions applies:

Users have given their consent for one or more specific purposes; Note: In some jurisdictions the Controller may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Controller is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Controller;
processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

It is always possible to request the Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract, or necessary to conclude a contract.

Place

The Data is processed at the Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Controller.

The User’s Personal Data may be transferred to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Controller to safeguard their Data.

Users can check if any such transfer takes place by examining the section of this document containing details about the processing of Personal Data or inquire with the Controller using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Controller within the relevant sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may retain Personal Data longer until such consent is revoked. Furthermore, the Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Purposes of processing the collected Data

The Data concerning the User is collected to allow the Controller to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following: Analytics, Contact management and sending messages, Tag Management and Displaying content from external platforms.

To obtain detailed information about the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

Contact management and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Tag Management
This type of service helps the Controller to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy.
Font Awesome (Fonticons, Inc.)
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; Tracking Tool.
Place of processing: United States – Privacy Policy.

Information on how to opt-out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt-out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Controller.

In particular, Users have the right to do the following:

withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
access their Data. Users have the right to learn if Data is being processed by the Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Controller will not process their Data for any purpose other than storing it.
have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Controller.
receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
lodge a complaint. Users have the right to bring a claim before their competent data protection authority or act in a judicial seat.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Controller or for the purposes of the legitimate interests pursued by the Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Controller is processing Personal Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Controller as early as possible and always within one month.

Cookie Policy

This Website uses Tracking Tools. To learn more, the User can consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Controller in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Controller may be required to reveal personal data upon request of public authorities.

Specific information

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Controller at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Controller shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The hardware or software tool by which the Personal Data of the User is collected and processed.

Service

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

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

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

Tracking Tool

Tracking Tool indicates any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by collecting or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Unless otherwise stated, this privacy policy relates solely to this Website.