The following privacy policy is intended to explain clearly and transparently the data we collect about you.
Information notice pursuant to EU Regulation 2016/679 (“GDPR”)
– Contacting the User: Contact form
Personal Data: various types of Data
– Spam protection: Akismet
Personal Data: Cookies and Usage Data
– Advertising: Facebook Audience Network
Personal Data: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example)
– Remarketing and behavioral targeting: Facebook Remarketing, AdWords Remarketing and Remarketing with Google Analytics for display advertising
Personal Data: Cookies and Usage Data
– Facebook Custom Audience
Personal Data: Cookies and email
– Analytics: Google Analytics, Google Analytics with anonymized IP, Facebook Ads conversion tracking, Display Advertisers extension for Google Analytics and directly collected statistics
Personal Data: Cookies and Usage Data
– Tag Management: Google Tag Manager
Personal Data: Cookies and Usage Data
– Facebook Analytics for Apps
Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service
– User ID extension for Google Analytics
Personal Data: Cookies
– Displaying content from external platforms: Google Fonts, YouTube
Data Controller:
Tsubomi srl, VAT No. 03037150996, Address: VIA MONTE SUELLO 18/9 – 16129 – GENOVA (GE), PEC: tsubomi.srl@pecdotcom.it
Among the Personal Data collected by this Application, independently or through third parties, there are: Cookies, Usage Data, various types of Data, email and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
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 collection itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate it, it may be impossible for this Application to provide the Service. In cases where this Application 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 Application or by the owners of third-party services used by this Application, 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 Application and guarantees that they have the right to communicate or disseminate them, releasing the Controller from any liability towards third parties.
Processing methods
The Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal personnel, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Controller, may have access to the Data. The updated list of Processors may always be requested from the Data Controller.
Legal basis for processing
The Controller processes Personal Data relating to the User if one of the following conditions exists:
It is however 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 the 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 place where the parties involved in the processing are located. For further information, contact the Controller.
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 details on the processing of Personal Data.
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 of public international law or set up by two or more countries, such as the UN, as well as regarding the security measures adopted by the Controller to protect the Data.
Should one of the transfers described above take place, the User can refer to the respective sections of this document or request information from the Controller by contacting them at the details provided at the beginning.
Retention period
The Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
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 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, at the expiry of this term, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.
The User’s Data is collected to allow the Controller to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Remarketing and behavioral targeting, Advertising, Tag Management, SPAM protection and Displaying content from external platforms.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.
Personal Data is collected for the following purposes and using the following services:
Contacting the User
Contact form (this Application)
The User, by filling in the contact form with their Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header.
Personal Data collected: various types of Data.
Tag Management
This type of service is functional to the centralized management of tags or scripts used on this Application.
The use of such services involves the flow of User Data through them and, if applicable, their retention.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc.
The use of the system is subject to the privacy policy of Automattic Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – privacy policy. Privacy Shield participant.
Advertising
This type of service allows User Data to be used for commercial communication purposes in various advertising forms, such as banners, also in relation to the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.
Some of the services indicated below may use Cookies to identify the User or use the behavioral retargeting technique, i.e. display advertisements personalized based on the User’s interests and behavior, also 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 possibilities offered by the services listed below, the User can opt for exclusion from receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook’s data use, please consult Facebook’s data policy.
To allow Facebook Audience Network to function, this Application may 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 their advertising preferences within the Facebook Ad settings.
The User can opt-out from some Audience Network targeting functions through their device settings. For example, they can change the advertising settings available for mobile devices, or follow the instructions applicable to Audience Network that may be present within this privacy policy.
Personal Data collected: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Remarketing and behavioral targeting
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User’s past use of this Application.
This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to whom the remarketing and behavioral targeting activity is connected.
In addition to the opt-out possibilities offered by the services listed below, the User can opt for exclusion from receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
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.
Personal Data collected: Cookies and email.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Remarketing with Google Analytics for display advertising (Google Inc.)
Google Analytics for display advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity carried out by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Analytics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“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 Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“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 Personal Data to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries participating in the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google’s servers and shortened within the United States.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is a statistics service provided by Facebook, Inc. that connects data from the Facebook ad network with actions performed within this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Display Advertisers extension for Google Analytics (Google Inc.)
Google Analytics on this Application may use Google’s interest-based advertising, third-party audience data and information from the DoubleClick Cookie to extend statistics with demographic data, interests and data on interactions with advertisements.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
User ID extension for Google Analytics (Google Inc.)
Google Analytics on this Application uses a function called User ID. This allows for more accurate tracking of Users by assigning each one a unique ID for various sessions and devices, but in such a way as not to allow Google to personally identify an individual or permanently identify a specific device.
The User ID extension also allows connecting Data from Google Analytics with other Data relating to the user collected by this Application.
The Opt Out link provided below allows you to deactivate tracking for the device you are using, but does not exclude further tracking activities carried out by the Controller. To deactivate the latter as well, contact the controller via the contact email address.
Personal Data collected: Cookies.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Directly collected statistics (this Application)
This Application uses an internal statistics system, which does not involve third parties.
Personal Data collected: Cookies and Usage Data.
Displaying 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 interact with them.
In the event that a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages in which it is installed.
Google Fonts (Google Inc.)
Google Fonts is a typeface style display service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
YouTube
YouTube is a video streaming service managed by Google Inc. that allows this Application to show video content to users.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Users can exercise certain rights with reference to the Data processed by the Controller.
In particular, the User has the right to:
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller or to pursue a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are informed that, should their Data be processed for direct marketing purposes, they can object to the processing without providing any reason. To find out if the Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights
To exercise User rights, Users can direct a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as quickly as possible, in any case within one month.
This Application uses Cookies. To learn more and to view the detailed information notice, the User can consult the Cookie Policy.
Legal defense
The User’s Personal Data may be used by the Controller in court or in the preparatory stages for its eventual establishment for defense against abuse in the use of this Application or connected Services by the User.
The User declares to be aware that the Controller may be obliged to reveal the Data by order of public authorities.
Specific information notices
At the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
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 interactions and which may also contain Personal Data, such as the User’s IP address.
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.
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.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in the Controller’s possession. Please therefore consult this page regularly, referring to the date of last modification indicated at the bottom.
Should the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This is information collected automatically through this Application (also by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used in forwarding 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 the operating system used by the visitor, the various time 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 to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
User
The individual using this Application 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 person, legal person, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.
Data Controller (or Controller)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which the Personal Data of Users is collected and processed.
Service
The Service provided by this Application as defined in the relative terms (if present) on this site/application.
European Union (or EU)
Unless otherwise specified, every 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.
Cookie
Small portion of data stored inside the User’s device.
Legal references
This privacy policy is drafted on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy concerns exclusively this Application.
