Last updated: 29 September 2021
Portal “Krstarica” (“we” or “us” or “our”) respects the privacy of our users („users“, “user” or “you”). This Privacy and Cookie Policy explains how we collect, use, disclose, and safeguard your information when you use our websites, our mobile or Facebook applications, and/or any related services, sales, marketing or events (collectively, „Portal“).
Please read this Privacy and Cookie Policy carefully. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our website, applications and our services.
We reserve the right to make changes to this Privacy and Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date on this page. Any changes or modifications will be effective immediately upon posting the updated Privacy and Cookie Policy on this page.
Collection of your information
Portal collects some Personal Data from its Users.
Owner and Data Controller
Portal can be contacted using the contact form.
Types of Data collected
Among the types of Personal Data that Portal collects, by itself or through third parties, there are:
first name, last name, company name, email address, Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geographic position, various types of Data, Camera permission, Approximate location permission (non-continuous), Storage permission, Social media accounts permission and language.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Portal.
Unless specified otherwise, all Data requested by Portal is mandatory and failure to provide this Data may make it impossible for Portal to provide its services. In cases where Portal specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Portal or by the owners of third-party services used by Portal serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Portal and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Portal (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 Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner 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 Owner 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 Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data 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 Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner 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 Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’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 Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner 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 to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
Contacting the User, Advertising, Analytics, Traffic optimization and distribution, Infrastructure monitoring, Data transfer outside the EU, Device permissions for Personal Data access, Remarketing and behavioral targeting, Access to third-party accounts, Registration and authentication, Interaction with external social networks and platforms, Managing contacts and sending messages, Location-based interactions, Displaying content from external platforms, Tag Management, Commercial affiliation, SPAM protection and Content commenting.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Facebook permissions asked by Portal
Portal may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Portal to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Email
Provides access to the User’s primary email address.
Device permissions for Personal Data access
Depending on the User’s specific device, Portal may request certain permissions that allow it to access the User’s device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of Portal.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Portal.
Approximate location permission (non-continuous)
Used for accessing the User’s approximate device location. Portal may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Portal to derive the approximate position of the User on a continuous basis.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Social media accounts permission
Used for accessing the User’s social media account profiles, such as Facebook and Twitter.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows Portal to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Portal)
This service allows Portal to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Email.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Portal, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Portal. For more information, please check the privacy policies of the relevant services.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
AdMob
AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
In order to understand Google’s use of Data, consult Google’s partner policy.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States and Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
This service uses the “Doubleclick” Cookie, which tracks use of Portal and User behavior concerning ads, products and services offered.
Users may decide to disable all the Doubleclick Cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.
Portal may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Google AdSense
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from. This service uses the “Doubleclick” Cookie, which tracks use of Portal and User behavior concerning ads, products and services offered.
Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
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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.
Analytics collected directly (Portal)
Portal uses an internal analytics system that does not involve third parties.
Personal Data collected: Cookies and Usage Data.
ComScore Analytics (ComScore, Inc.)
ComScore is an analytics service provided by ComScore, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Display Advertising extension for Google Analytics
Google Analytics on Portal might use Google’s Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
Fabric Answers
Fabric Answers is an analytics service provided by Crashlytics, a business division of Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
In order to understand Google’s use of Data, consult Google’s partner policy.
This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Fabric Answers privacy policy.
In particular, Portal uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Fabric Answers service.
Fabric Answers may share Data with other tools provided by Fabric/Crashlytics, such as Crashlytics or Twitter. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
Users may opt-out of certain Fabric Answers features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Fabric related sections of this privacy policy, if available.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States and Ireland – Privacy Policy.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Portal.
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.
Google AdWords conversion tracking
Google AdWords conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that connects data from the Google AdWords advertising network with actions performed on Portal.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from. Google utilizes the Data collected to track and examine the use of Portal, 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 collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from. In order to understand Google’s use of Data, consult Google’s partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
Portal uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Quantcast Measure (Quantcast Corporation)
Quantcast Measure is an analytics service provided by Quantcast Corporation.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Twitter Ads conversion tracking (Twitter, Inc.)
Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Portal.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Commercial affiliation
This type of service allows Portal to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Portal.
For details of which data are collected, please refer to the privacy policy of each service.
Amazon Affiliation (Amazon)
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
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Contacting the User
Contact form (Portal)
By filling in the contact form with their Data, the User authorizes Portal to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: company name, email address, first name and last name.
Mailing list or newsletter (Portal)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Portal. Your email address might also be added to this list as a result of signing up to Portal or after making a purchase.
Personal Data collected: company name, email address, first name and last name.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Portal.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (Portal)
Portal has its own internal content comment system.
Personal Data collected: email address, first name and last name.
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer abroad based on standard contractual clauses (Portal)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data collected: various types of Data.
Data transfer to countries that guarantee European standards (Portal)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.
Personal Data collected: various types of Data.
Data transfer abroad based on consent (Portal)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Portal.
Personal Data collected: various types of Data.
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Device permissions for Personal Data access
Portal requests certain permissions from Users that allow it to access the User’s device Data as described below.
Device permissions for Personal Data access (Portal)
Portal requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.
Personal Data collected: Approximate location permission (non-continuous), Camera permission, Social media accounts permission and Storage permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Portal 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 Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that allows Portal to incorporate content of this kind on 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 and Ireland – Privacy Policy. Privacy Shield participant.
Google Site Search
Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that allows Portal to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows Portal to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data collected: email address and Usage Data.
Place of processing: United States – Privacy Policy.
YouTube video widget
YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that allows Portal to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows Portal to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
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Infrastructure monitoring
This type of service allows Portal to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Portal.
Crashlytics
Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.
Place of processing: United States and Ireland – Privacy Policy.
Firebase Performance Monitoring
Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Portal.
The interaction and information obtained through Portal are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
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 collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
YouTube button and social widgets
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
Personal Data collected: Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Location-based interactions
Geolocation (Portal)
Portal may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Portal.
Personal Data collected: geographic position.
Non-continuous geolocation (Portal)
Portal may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Portal.
The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data collected: geographic position.
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Managing contacts 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.
Firebase Cloud Messaging
Firebase Cloud Messaging is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Firebase Notifications
Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
OneSignal (Lilomi, Inc.)
OneSignal is a message sending service provided by Lilomi, Inc.
OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Depending on the permissions granted to Portal, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User’s device. Portal uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.
The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal’s use of Data, consult OneSignal’s privacy policy.
Push notifications opt-out
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones.
Different device configurations, or updates to devices, may affect or change how these indicated settings work.
Personal Data collected: Cookies, email address, geographic position, language, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
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Registration and authentication
By registering or authenticating, Users allow Portal to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Portal will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Direct registration (Portal)
The User registers by filling out the registration form and providing the Personal Data directly to Portal.
Personal Data collected: company name, email address, first name and last name.
Google OAuth
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, and is connected to the Google network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
Twitter OAuth (Twitter, Inc.)
Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Remarketing and behavioral targeting
This type of service allows Portal and its partners to inform, optimize and serve advertising based on past use of Portal by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
Google Ad Manager Audience Extension
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from, that tracks the visitors of Portal and allows selected advertising partners to display targeted ads across the web to them.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Portal with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Portal with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
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SPAM protection
This type of service analyzes the traffic of Portal, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Portal 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 Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location Portal is accessed from.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States and Ireland – Privacy Policy. Privacy Shield participant.
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Traffic optimization and distribution
This type of service allows Portal to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Portal and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
CloudFlare (Cloudflare)
CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc.
The way CloudFlare is integrated means that it filters all the traffic through Portal, i.e., communication between Portal and the User’s browser, while also allowing analytical data from Portal to be collected.
Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Further information about Personal Data
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Push notifications
Portal may send push notifications to the User.
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Unique device identification
Portal may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Portal depends on the payment system used.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
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 Owner, 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 Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner by contacting the Owner through the contact details provided in this document.
- 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.
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 Owner or for the purposes of the legitimate interests pursued by the Owner, 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 Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
Portal uses Cookies. Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User’s consent.
Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.
Technical Cookies and Cookies serving aggregated statistical purposes
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Activity strictly necessary for the functioning of the Service
Portal uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of Portal, for example in relation to the distribution of traffic.
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Activity regarding the saving of preferences, optimization, and statistics
Portal uses Cookies to save browsing preferences and to optimize the User’s browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.
Other types of Cookies or third parties that install Cookies
Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.
If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.
How to provide or withdraw consent to the installation of Cookies
In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies.
Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party’s privacy policy, or by contacting the third party.
Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
Installation of third-party Cookies
Since the installation of third-party Cookies and other tracking systems through the services used within Portal cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.
Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by Portal.
Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Portal or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, Portal 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, Portal and any third-party services may collect files that record interaction with Portal (System logs) 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 Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Portal 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 Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Portal and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. 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 Owner 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 Portal (or third-party services employed in Portal), which can include: the IP addresses or domain names of the computers utilized by the Users who use Portal, 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 within the Application) 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 Portal who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
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 Owner)
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 Portal. The Data Controller, unless otherwise specified, is the Owner of Portal.
Portal
(or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Portal 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.
Cookies
Small sets of data stored in 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).
This privacy policy relates solely to Portal, if not stated otherwise within this document.