PRIVACY POLICY of www.arnaldocastelli.it The "owner" of their treatment is the company Arnaldo Castelli, with registered office via Pontaccio 12 / A, 20121 Milan. Vat.no: IT 12672360968 Owner contact email: mail@arnaldocastelli.it Types of Data collected Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Tracker; Usage Data; email address; phone number; city; country; Universally unique identifier (UUID); answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; number of Users; device information; session statistics; latitude (of city); longitude (of city); browser information. 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 this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 this Website or by the owners of third-party services used by this Website 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 this Website and confirm that they have the third party's consent to provide the Data to the Owner. Mode and place of processing the DataMethods of processing The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational 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 this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the 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 organisation 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 enquire 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 of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period. The purposes of processing The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, User database management, Managing contacts and sending messages, Advertising, Remarketing and behavioural targeting, Managing data collection and online surveys, Displaying content from external platforms and SPAM protection. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”. Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services: 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. CoffeeCup Software (CoffeeCup Software,Inc.) CoffeeCup Software Email is an email address management and message sending service provided by HubSpot, Inc. Personal Data processed: email address; Usage Data. Place of processing: United States – Privacy Policy. Category of personal information collected according to CCPA: identifiers; internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. User database management This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website. CoffeeCup Software(CoffeeCup Software Inc.) is a User database management service provided by CoffeeCup Software, Inc. Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Category of personal information collected according to CCPA: identifiers; internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. CoffeeCup Software(CoffeeCup Software, Inc.)CoffeeCup Softwareè Lead Management is a User database management service provided by HubSpot, Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Category of personal information collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Managing data collection and online surveys This type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users. The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form. These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing. SPAM protection This type of service analyses the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM. Google reCAPTCHA (Google Ireland Limited)Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited. The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data. Place of processing: Ireland – Privacy Policy. Category of personal information collected according to CCPA: internet information; inferred information. Advertising This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, 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 Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Website. For more information, please check the privacy policies of the relevant services. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document. Facebook Lookalike Audience (Meta Platforms Ireland Limited) Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services. On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page. Personal Data processed: Tracker; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out. Category of personal information collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. AddThis (Oracle Corporation) AddThis is an advertising and behavioural targeting service provided by Oracle Corporation that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Website and connects the activity of this Website with the Oracle advertising network. Users can opt out of Oracle's use of Trackers for ads personalisation by visiting this opt-out page. Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data. Place of processing: United States – Privacy Policy – Opt out. Category of personal information collected according to CCPA: identifiers; internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Remarketing e behavioral targeting This type of service allows this Website and its partners to inform, optimise and serve advertising based on past use of this Website by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity. Some services offer a remarketing option based on email address lists. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.Google Fonts (Google Ireland Limited) Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages. Personal Data processed: Tracker; Usage Data. Place of processing: Ireland – Privacy Policy. Category of personal information collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Informazioni su come disattivare gli annunci pubblicitari basati sugli interessi Oltre a qualsiasi funzione di opt-out fornita da uno qualsiasi dei servizi elencati in questo documento, gli Utenti possono leggere di più su come disattivare gli annunci pubblicitari basati sugli interessi nell'apposita sezione della Cookie Policy.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, under certain circumstances, to obtain the erasure of their Data from the Owner. -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. 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 this Website, if not stated otherwise within this document. Latest update: : 22 october 2022