Privacy Policy of www.erbital.it
This Application collects some Personal Data from its Users.
Data Controller
ERBITAL DI CAVALLO MARCO – Via Gerbidi s.n.c. 13038 tricerro (VC)
Owner’s email address: INFO@ERBITAL.IT
Types of Data collected
Among the Personal Data collected by this Website, independently or through third parties, there are: email; password; Tracking Tool; Usage data; Data communicated while using the service; device information; purchase history; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); various types of Data; first name; surname; Billing information; Universally Unique Identifier (UUID).
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website 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 mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing 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 responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.
Method and place of processing of the collected Data
Methods of treatment
The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.
Legal basis of the treatment
Il Titolare tratta Dati Personali relativi all’Utente in caso sussista una delle seguenti condizioni:
- 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 of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
- the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the treatment is necessary for the execution of a task of public interest or for the exercise of public powers with which the Data Controller is invested;
the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.
However, it is always possible to ask the Data Controller 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 is 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 processing, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
Periodo di conservazione
The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
- 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.
- Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the treatment is based on the User’s consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep 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 expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purpose of the processing of the collected data
The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any malicious activity or fraudulent, as well as for the following purposes: Contacting the User, Registration and authentication provided directly by this Website, Access to accounts on third-party services, Statistics, Viewing content from external platforms, Managing contacts and sending messages, Handling requests support and contact, Hosting and backend infrastructure, Remarketing and behavioral targeting, Infrastructure monitoring, Payment management, Commercial affiliation, Tag management, Interaction with external social networks and platforms, Data transfer outside the EU, Interaction with live chat platforms, User database management, Interaction with collection platforms data and other third parties, Advertising, Registration and authentication, Web conferencing and online telephony management, Content and functionality performance testing (A/B testing), Information collection and Data Linking.
Facebook permissions requested by this website
This Website may ask for some Facebook permissions which allow it to perform actions with the User’s Facebook account and to collect information, including Personal Data, from it. This service allows this Website to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information on the permissions below, please refer to the Facebook permissions documentation and Facebook’s privacy policy.
The permissions required are as follows:
Basic information
The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and localization language and, in some cases, the “Friends” of Facebook. If the User has made additional Data publicly available, the same will be available.
Email
Provides access to the User’s primary email address.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Registration and authentication provided directly by this website
By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services. Personal Data is collected and stored solely for registration or identification purposes. The Data collected are only those necessary to provide the service requested by the User.
Direct Registration (this Website)
The User registers by filling out the registration form and providing his/her Personal Data directly to this Website.
Personal Data processed: email; password.
Legal basis for processing: Consent.
Legal basis for data transfer outside the EU: No data transfer.
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 behaviour.
Google Ads conversion tracking
Google Ads conversion tracking is a statistics service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, which connects data from the Google Ads advertising network with actions performed within this website.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Google Analytics con IP anonimizzato
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.
This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened within the United States.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Twitter Ads conversion tracking (Twitter, Inc.)
Twitter Ads conversion tracking is a statistics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
User ID extension for Google Analytics
Google Analytics on this Website uses a function called User ID. This allows more accurate tracking of Users by assigning each one a unique ID for various sessions and devices, but in such a way as not to allow Google to personally identify an individual or permanently identify a specific device.
The User ID extension also allows you to connect Data from Google Analytics with other User Data collected by this Website.
Personal Data processed: Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Advertising Reporting Features in Google Analytics
Google Analytics on this Website has Advertising Reporting Features enabled, which collect additional information from the DoubleClick cookie (web activity) and device advertising IDs (application activity). This allows the Owner to analyze specific Data relating to Users’ behaviors and interests (Traffic data and User interaction data with ads) and, if enabled, Demographic Data (information on age and gender).
Users can choose not to use Google cookies by visiting Google’s [Ad settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool; various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Google Analytics demographics and interests reports
Google Analytics Demographics and Interests Reporting is an advertising reporting feature that makes Demographics and Interests Data available within Google Analytics for this Website (Demographics means Age and Gender Data ).
Users can choose not to use Google cookies by visiting Google’s [Ad settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
LinkedIn Conversion Tracking (LinkedIn Corporation)
LinkedIn conversion tracking is a statistics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this website.
Personal Data processed: Usage data; device information; Tracking Tool.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: Data retention for the time necessary to achieve the purpose.
Contact the user
Mailing List or Newsletter (this Website)
By registering with the mailing list or newsletter, the User’s email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Website may be sent. User’s email address could also be added to this list as a result of registering on this Website or after making a purchase.
Personal Data processed: email.
Legal basis for processing: Consent.
Tag management
This type of service is functional for the centralized management of the tags or scripts used on this Website.
The use of these services involves the flow of User Data through them and, where appropriate, their retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage data.
Place of processing: Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: 18 months.
Interactions with social networks
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User’s privacy settings relating to each social network.
This type of service could still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out of the respective services to ensure that the data processed on this Website is not reconnected to the User’s profile.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services allowing interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
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 processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: 3 months.
Registration and Authentication
By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services.
Depending on what is indicated below, the registration and authentication services could be provided with the help of third parties. If this happens, this Website will be able to access some Data stored by the third party service used for registration or identification.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, please refer to the description of each service.
Hosting and infrastructure
This type of service has the function of hosting Data and files that allow this Website to function, allow its distribution and provide a ready-to-use infrastructure to deliver specific functions of this Website.
Some of the services listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
The infrastructure is located in France and is provided by the company:
OVH Srl (Single shareholder) Share capital €. 10,000.00 fully paid up
Tax Code and VAT number 06157670966 Milan Company Register No. 06157670966
REA No. 1873458.
Registered office: Via Carlo Imbonati, 18 20159 Milan
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 previously expressed consent to the processing of his Personal Data.
oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.
obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
receive their data or have them transferred to another owner. The User has the right to receive their Data in a 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 are processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons connected with their particular situation.
Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise your rights
To exercise the User’s rights, Users can direct 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 a month.
Learn more about 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 related Services by the User.
The User declares to be aware that the Owner may be obliged 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 and maintenance logs
For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which 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 as well as, if technically and legally feasible, by sending a notification to Users via one of the contact details held by the Data Controller. Therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
User
The individual who uses this Application who, unless otherwise specified, coincides with the interested party.
Interested
The natural person to whom the Personal Data refer.
Data Processor (or Manager)
The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, according to what is set out in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures relating to the functioning and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which the Personal Data of Users are 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, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.
Cookies
Small portion of data stored within the User’s device.
Legal references
This privacy statement has been prepared on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy statement applies exclusively to this Application.