Privacy policy and terms of use

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Privacy policy and terms of use2018-09-30T19:58:09+00:00

Terms and Conditions

Welcome to ilspanish.com, the premier service for people around the world to learn languages online. This agreement (the “Agreement”) represents the entire contract between you and International Language Spanish – ILS with respect to the above mentioned site(s) (the “Site”) and, if applicable, the fee-based subscription services therein. By visiting, becoming a customer of, purchasing a gift subscription from, or subscribing to International Language Spanish – ILS, you agree, without qualification, to be bound by the terms and conditions (the “Terms”) of use set out below.

  1. Acceptance of the Terms
  2. Changes to these Terms
  3. Provision of the Services
  4. Your Rights
  5. Use of the Service
  6. Intellectual Property Rights
  7. Access and Interference
  8. Privacy and Security Policy
  9. Community forums, chats, message boards, and email conduct
  10. Fees and payments
  11. Indemnification
  12. Miscellaneous

1. Acceptance of the Terms

By using the information, tools, features and functionality located on ilspanish.com (together the “Service” or the “Services”), you agree to be bound by this Agreement and the Terms, whether you are a “Visitor” (which means that you simply browse the International Language Spanish – ILS website) or you are a “Customer” (which means that you have registered with International Language Spanish – ILS). The term “you” or “User” refers to a Visitor or a Customer. The term “we” refers to International Language Spanish – ILS . The term “Material” refers to all class materials used in our classes. If you wish to become a Customer, communicate with other Customers and/or make use of the Service, you must read this Agreement and indicate your acceptance during the registration process.

If you do not agree with all the Terms, do not use the Site.

Please review all of the Terms carefully before using the Site.

By using the Site, you agree to be bound by the Terms and confirm that you are over the age of 13 and able to form legally binding contracts.

Before you continue, you should print or save a local copy of this Agreement for your records.

2. Changes to these Terms

International Language Spanish – ILS  has the right to modify this Agreement and any policies affecting or pertaining to the Site. Your continued use of the Site following notice of the Agreement modification will be considered an acceptance of the modified terms and conditions of use. Your recourse upon dissatisfaction with the modified terms of use is to cancel your subscription by following the instructions set out above. Furthermore, International Language Spanish – ILS  reserves the right to modify, suspend or discontinue the Site at any time.

3. Provision of the Services

In providing the Services, we do not actively monitor the display, transmission and exchange of Material that is accessible by means of the Services, nor do we maintain any obligation to do so except as otherwise determined by us or required by the laws of applicable jurisdictions. However, subject to the terms of our Privacy and Security Policy, we reserve the right to monitor the Services for purposes of determining that their usage is in compliance with these Terms and applicable laws. In addition, and as described elsewhere in these Terms, we maintain an absolute and unconditional right to review and remove Material accessible by or transmitted through the Services that, in our sole discretion, we believe is in violation of the law of these Terms or is unacceptable to us in our sole discretion.

From time to time and without prior notice to you, we may change, expand and improve the Site and Services. We may also, at any time, cease to continue operating part or all of the Services or selectively disable certain aspects of the Services or portions of the Site. Any modification or elimination of the Services will be done in our sole and absolute discretion and without an ongoing obligation or liability to you, and your use of the Site and Services do not entitle you to the continued provision or availability of the Site and Services.

4. Your Rights

International Language Spanish – ILS  offers you a non-transferable, non-exclusive, limited right to access, use and display the content of this Site, provided that you comply with this Agreement and the Terms as set out in full. The materials of this Site are provided to you only for your private, non-commercial use. Certain services of this Site are available only to registered customers of International Language Spanish – ILS.

By electing to purchase a subscription or register for a trial of International Language Spanish – ILS, you agree to be bound by the terms and conditions set out below in section 10 in the International Language Spanish – ILS billing policy.

5. Use of the Service

Your right to access and use ilspanish.com and the Service is personal to you and is not transferable by you to any other person or entity. You are only entitled to access and use International Language Spanish – ILS for lawful purposes.

You are responsible for maintaining the secrecy of your International Language Spanish – ILS account (the “Account”), username and password. You agree to notify International Language Spanish – ILS of any unauthorized use of your International Language Spanish – ILS Account. In order for the Service to function effectively, you must also keep your registration information up to date and accurate. If you do not do this, the accuracy and effectiveness of the Service to you will be affected.

In our sole and absolute discretion, we may terminate your Account, or modify, reclaim or remove any username associated with your Account, for any reason (including for reasons related to unlawful or unauthorized usage) and we are under no obligation to retain a record of your Account or any data or information that you may have stored by means of the Account and/or the Services.

Your access and use of ilspanish.com may be interrupted from time to time for any of several reasons, including, without limitation, the malfunction of equipment, periodic updating, maintenance or repair of ilspanish.com or other actions that International Language Spanish – ILS, in its sole discretion, may elect to take. International Language Spanish – ILS is not responsible for any loss resulting from your using any of Language services, software, materials, audio or video files, content, or communications.

6. Intellectual Property Rights

All materials of International Language Spanish – ILS, including content, text, images, software, audio and video files, documentation, Email English and the Site remain at all time the sole property of International Language Spanish – ILS or its suppliers except the images, text, images, software, audio and video files, documentation refer to others sources. Such aforementioned materials are protected under international copyright, trademark and other intellectual property laws. You may not post, distribute, sublicense, translate or reproduce in any way any copyrighted materials, trademarks or other proprietary information without the prior express written consent of International Language Spanish – ILS.

7. Access and Interference

You agree that you will not:

  • Use any robot, spider, scraper, deep link or other similar automated data gathering or extraction tools, program, algorithm or methodology to access, acquire, copy or monitor ilspanish.com or any portion of ilspanish.com, without International Language Spanish – ILS’s express written consent, which may be withheld in International Language Spanish – ILS’s sole discretion;
  • Use or attempt to use any engine, software, tool, agent, or other device or mechanism (including without limitation browsers, spiders, robots, avatars or intelligent agents) to navigate or search ilspanish.com, other than the search engines and search agents available through the Service and other than generally available third-party web browsers (such as Microsoft Explorer);
  • Post or transmit any file which contains viruses, worms, Trojan horses or any other contaminating or destructive features, or that otherwise interfere with the proper working of ilspanish.com or the Service;
  • Attempt to decipher, decompile, disassemble, or reverse-engineer any of the software comprising or in any way making up a part of ilspanish.com or the Service. Please be aware that your carrier’s normal rates and fees, such as text messaging fees, will apply when accessing ilspanish.com with your portable devices.

8. Privacy and Security Policy

Your use of our Site and any personal information or other information about you collected by ilspanish.com through, or in connection with, the Site (other than User Generated Content) is subject to our Privacy and Security Policy.

As indicated in the Terms, our Site is not designed to attract children under the age of 13. We do not knowingly collect personally identifying information from anyone under the age of 13 unless we first obtain permission from that child’s parent or legal guardian.

For questions about our online privacy and security policy for children please refer to the Privacy and Security Policy.

9. Community forums, chats, message boards, and email conduct

International Language Spanish – ILS strives to create a global community of language learners. As such, International Language Spanish – ILS provides users with the ability to post messages, use chat rooms, and find learning resources, such as local language schools and job offers. You are solely responsible for the content of these messages as set out in this Agreement. In addition, by using these services, you agree to not publish, contribute or post any material that:

  • Contains content that is not original or for which you have not received the prior express written consent of the originator of said material.
  • Contains objectionable language or is in any way profane, pornographic, sexually explicit, slanderous or libelous.
  • Attempts to contact a fellow user of International Language Spanish – ILS without explicit solicitation by that user.
  • Violates any viable rules, laws or regulations, or infringes on any rights of any third party.
  • Contains viruses or any other code designed to interrupt, destroy or incapacitate the functionality of any software, hardware or telecommunications.
  • Is considered “spamming,” such as chain letters, junk mail, or other solicitations.
  • Attempts to impersonate another person or breach the security of International Language Spanish – ILS and its users.
  • The opinions and messages posted by users at International Language Spanish – ILS do not reflect and are not representative of the views of International Language Spanish – ILS or its employees, affiliates, suppliers or partners. International Language Spanish – ILS is not responsible for the content of messages sent by users to other users.

10. Fees and payments

You will be required to register and create an account with International Language Spanish – ILS (the “Account”) in order to access certain features of the Site and Services. Information gathered through the registration process and information related to your account will be subject to these Terms as well as to our “Privacy and Security Policy”. You represent and warrant that you will not create an Account for anyone other than yourself without permission, that all information provided by you when creating an Account is true, accurate and complete, and that you will maintain, at all times, true, accurate and complete information related to your Account.

Certain materials and functionalities of the Site are available only through the purchase of an online language class package. Pursuant to this Agreement you are responsible for any charges associated with connecting to the Site. International Language Spanish – ILS reserves the right to change the fees in effect or institute new fees at any time, upon reasonable notice posted on the site and emailed to current customers.

By purchasing a class or course you agree to be bound to the following terms:

Billing Policies

International Language Spanish – ILS fees are exclusive of any applicable VAT or taxes, interest or installment fees charged by the credit card company, or other fees associated with connecting to the Internet.

International Language Spanish – ILS guarantees that every credit card transaction you make at International Language Spanish – ILS is 100% secure. If at any time you wish to check on the status of your subscription, please login and visit the “My Account” page in your Login area.

Your language course contains teacher-led classes. Group classes and private classes are delivered on a “class credit basis”, giving you access to the stated amount of group classes and private classes that your language course offers. You can always find current prices of language courses posted in the checkout pages and occasionally in other pages of our website. The exact contents of your language courses are clearly set forth and accessible at all times in the logged-in section of the Site under “My account”.

All language course fees are recurring and non-refundable after your purchase. If you do not cancel your language course before the end of the stated course time, you agree to the automatic extension of your language course for the same time and the same terms. If you do not wish to continue your language course, you have to deactivate your account in the “My Account” page in your login area or give us written (email) notice.

An exception to the prior paragraph is our 7-day money back guarantee when stated explicitly on the checkout page. Within 7 days after purchase you have the right to cancel your language course by written (email) notice and receive your full money back.

In addition to the classes included in your language course, you can purchase additional classes. These classes give you the right to take more teacher-led classes. Additional classes, whether group or private, those sessions are delivered on a “class credit basis” over a period of 3 months, this means that if you haven’t used those sessions by the end of 3 months after purchasing the class package, those unused sessions are lost to you and will not be refunded.

Free trial

The free trial is available only to first-time users.

Credit card payments

After initial enrollment, if your credit card expires, is cancelled, is lost, or rendered invalid, your subscription is in danger of termination. You will be contacted and given the opportunity to change your registration data. If your credit card is not successfully recharged and you are not renewed successfully, your subscription will be terminated.

11. Indemnification

You agree to indemnify, defend and hold harmless International Language Spanish – ILS and its affiliates, partners, suppliers, and employees from any and all liability, claims, costs, or damages arising from your use of the Site or your breach of this Agreement and any of the Terms set out herein.

12. Miscellaneous

This Agreement represents the entire understanding and agreement between you and International Language Spanish – ILS regarding the subject matter of the same, and supersedes all other previous agreements.

If you have any questions about this policy statement, or about any of International Language Spanish – ILS’s other policies and practices, please contact us on the contact details laid out on ilspanish.com.

ilspanish.com and related services are, if not otherwise specifically mentioned, supplied by:

International Language Spanish – ILS

Conde Duque 3, 28015

Madrid (Spain)

Cookie Policy

This Application uses Cookies.

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 this Application 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, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (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

This Application 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 this Application 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 this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, 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 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 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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application 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.

About Me

Provides access to the ‘About Me’ section of the profile.

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 Application, if not stated otherwise within this document.

Latest update: May 24, 2018

Privacy Policy of www.ilspanish.com

This Application collects some Personal Data from its Users.

Owner and Data Controller

International Language Spanish-ILS, Conde Duque 3, 28015 Madrid (Spain)

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, various types of Data, first name, last name, date of birth, phone number, address, email address, password, company name, country, state, ZIP/Postal code, city, billing address, house number, data relating to the point of sale, language, profile picture, geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and About Me.

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 Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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 Application or by the owners of third-party services used by this Application 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 Application 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 this Application (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, 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: Access to third-party accounts, Analytics, Remarketing and behavioral targeting, Handling payments, Backup saving and management, Hosting and backend infrastructure, Advertising, Data transfer outside the EU, Registration and authentication, Managing contacts and sending messages, Interaction with external social networks and platforms, Location-based interactions, Displaying content from external platforms, Tag Management, User database management, Infrastructure monitoring, Contacting the User, Managing landing and invitation pages, Managing support and contact requests, Interaction with support and feedback platforms, Commercial affiliation, Content commenting and Interaction with live chat platforms.

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.

Detailed information on the processing of Personal Data

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

Access to third-party accounts

This type of service allows this Application 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.

Stripe account access (Stripe Inc)

This service allows this Application to connect with the User’s account on Stripe, provided by Stripe, Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

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 this Application, 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 this Application. 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.

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.

This Application 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 PolicyOpt Out. Privacy Shield participant.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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 – Privacy PolicyOpt Out.

Analytics collected directly (this Application)

This Application uses an internal analytics system that does not involve third parties.

Personal Data collected: Cookies and Usage Data.

Display Advertising extension for Google Analytics (Google Inc.)

Google Analytics on this Application 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 – Privacy PolicyOpt Out. Privacy Shield participant.

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 this Application.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Ads conversion tracking (Google Inc.)

Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Application.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

LinkedIn conversion tracking (LinkedIn Corporation)

LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

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.

Backup saving and management

This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.

Backup on Google Drive (Google Inc.)

Google Drive is a service to save and manage backups provided by Google Inc.

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.

Jetpack (WordPress Inc.)

Jetpack is a service to save and manage backups provided by WordPress Inc.

Personal Data collected: different types of Data, as specified in the Privacy Policy of the service.

Place of treatment: USA – Privacy Policy. Member of the “Privacy Shield” agreement.

Contacting the User

Mailing list or newsletter (this Application)

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 this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data collected: email address and first name.

Phone contact (this Application)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.

Personal Data collected: phone number.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Application.

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.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

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 (this Application)

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 from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)

If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.

In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.

Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

Personal Data collected: various types of Data.

Data transfer to countries that guarantee European standards (this Application)

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.

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.

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 Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application 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 – Privacy Policy. Privacy Shield participant.

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Handling payments

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

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.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Infrastructure monitoring

This type of service allows this Application 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 this Application.

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 this Application.

The interaction and information obtained through this Application 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.

PayPal button and widgets (PayPal Inc.)

The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: See the PayPal privacy policy – Privacy Policy.

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.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, for contacting and being contacted by this Application support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Facebook Messenger Customer Chat (Facebook, Inc.)

The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.

Personal Data collected: About Me, Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Interaction with support and feedback platforms

This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Application.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Location-based interactions

Geolocation (this Application)

This Application 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 this Application.

Personal Data collected: geographic position.

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.

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: email address.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Gmail (Google Inc.)
Email service provided by Google Inc.
Personal data collected: email address.
Place of treatment: USA – Privacy Policy. Member of the “Privacy shield” agreement.

Managing landing and invitation pages

This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.

Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

Managing support and contact requests

This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.

The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Registration and authentication

By registering or authenticating, Users allow this Application 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, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Direct registration (this Application)

The User registers by filling out the registration form and providing the Personal Data directly to this Application.

Personal Data collected: address, billing address, city, company name, country, data relating to the point of sale, date of birth, email address, first name, house number, language, last name, password, phone number, profile picture, state, various types of Data and ZIP/Postal code.

Linkedin OAuth (LinkedIn Corporation)

Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin 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.

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.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application 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.

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 PolicyOpt Out.

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 PolicyOpt Out. Privacy Shield participant.

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt 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 this Application with the Facebook advertising network.

Personal Data collected: Cookies and email address.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application 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 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.

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 Application, 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 Application.

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 Application.

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 Application, if not stated otherwise within this document.

Latest update: May 24, 2018

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