Privacy Policy

This Application collects some Personal Data from its Users.

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Owner of the data processing

The I Factor LTD - Unit C, 8th Floor, Jonsim Place, 228 Queens Road East
Owner email address: [email protected]

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Types of data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies, Usage data, email, surname and name.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this 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 on its operation.
Users who have doubts about which data are required are encouraged to contact the owner.
Any use of Cookies - or other tracking tools - by this Application or third party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

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

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Modalità e luogo del trattamento dei Dati raccolti

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

Legal basis of the processing
The Owner processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User's consent or another legal basis specified below, until the User objects ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Owner is subject;
• the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place
The Data are processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section concerning the details on the processing of Personal Data.
The User has the right to obtain information about the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
The User can check if one of the transfers described above takes place by examining the section of this document concerning the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.

Period of conservation
The Data is processed and stored for the time required for the purposes for which it was collected.
Therefore:

• The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the treatment is based on the consent of the User, the Owner may keep the Personal Data for longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

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Purposes of the processing of the collected data

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, Contacting the User.
To obtain further detailed information on the purposes of the processing and on the Personal Data that are specifically relevant for each purpose, the User may refer to the relevant sections of this document.

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Details on the processing of Personal Data

I Dati Personali sono raccolti per le seguenti finalità ed utilizzando i seguenti servizi:

Contact the user
Mailing list or newsletter (This Application)
By registering to the mailing list or to the newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, relating to this Application may be transmitted. The User's email address could also be added to this list as a result of registering with this Application or after making a purchase.
Personal Data collected: surname, email, name and telephone number.

Manage contacts and send messages
This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. These services could also allow you to collect data relating to the date and time of display of the messages by the User, as well asall’interazione dell'Utente con essi, come le informazioni sui click sui collegamenti inseriti nei messaggi.
MailChimp (The Rocket Science Group, LLC.)
Mailchimp is an address management and email message service provided by The Rocket Science Group, LLC.
Personal Data collected: surname, email, name and telephone number.
Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Management of landing pages and invitation pages
This type of service allows you to build and manage landing pages and invitation pages, that is, pages for presenting a product or service, which can allow you to enter your contact information, such as an email address. The management of these pages involves the processing, by these services, of the Personal Data collected through these pages, including those of the Usage Data.
MailChimp Landing Page (The Rocket Science Group, LLC.)
Mailchimp Landing Page is a landing page management service provided by The Rocket Science Group LLC which allows this Application to collect email addresses of the Users interested in its service.
Mailchimp Landing Page allows the Data Controller to keep track and analyze the response from the User, in terms of traffic or behavior, in relation to changes in the structure, text or any other component of the landing pages created.
Personal Data collected: surname, Cookie, email and name.
Place of processing: United States – Privacy Policy. Subject adherent to the Privacy Shield.

Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User 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 treatment: USA – Privacy Policy – Opt Out.

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User Rights

Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.
• object to the processing of your data. The User may object to the processing of his / her Data when it occurs on a legal basis other than consent. Further details on the opposition right are indicated in the section below.
• access your data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.
• get the treatment limitation. When certain conditions are met, the User may request the limitation of the processing of his / her Data. In this case, the Owner will not process the Data for any other purpose than their storage.
• obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.
• receive your data or have it transferred to another owner. The User has the right to receive his / her Data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the consent of the User, on a contract of which the User is a party or on contractual measures connected to it.
• to make a complaint. The User can propose a complaint to the competent personal data protection supervisory authority or act in court.

Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public authority over which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.
Users are reminded that, if their Data are processed for direct marketing purposes, they may oppose the processing without giving any reasons. To find out if the Data Controller treats data for direct marketing purposes, Users can refer to the respective sections of this document.

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

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Cookie Policy

This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.

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Further information on treatment

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

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

System log and maintenance
For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, that is files that record the interactions and that may also contain Personal Data, such as the User 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 and, if technically and legally feasible, by sending a notification to Users through one of the details of contact of which the Holder is in possession. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the modifications involve processing whose legal basis is consent, the Owner will collect the User consent again, if necessary.

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Definition and legal references

Personal Data (or Data)
Personal information is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an individual identified or identifiable.

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

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

Interested
The natural person to whom the Personal Data refers.

Data Processor (or Manager)
The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data and the instruments adopted, including security measures relating to the functioning and the 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 Users' Personal Data are collected and processed.

Service
The Service provided by this Application as defined in the relevant terms (if any) on this site / application.

European Union (o UE)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie
Small portion of data stored in the User's device.

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Legal references
This privacy statement is drafted on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy statement applies exclusively to this Application.

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Last edit: 28/02/2019