PRIVACY & COOKIE POLICY

This Site collects some Personal Data from its Users.

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Data Controller

 

Feel Fluent

via Raffaello Arcangelo Salimbeni 16, 00100 Rome

Owner email address: [email protected]

 

Types of data collected

 

Among the Personal Data collected by this site, independently or through third parties, there are: Cookies, e-mail, name, surname, username, password.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this site / platform.

Unless otherwise specified, all data requested by this site / platform are mandatory. If the User refuses to communicate them, it may be impossible for this site / platform to provide the Service. In cases where this site / platform 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 site / platform or by the owners of third party services used by this site / platform, 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 site / platform and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

 

Method and place of processing the collected data

Method of treatment

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The treatment 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 site / platform (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, couriers) may have access to the Data. postal, hosting provider, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: in some legal systems, 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 regulated by European legislation on the protection of Personal Data;
  • 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.
  • processing is necessary for the execution of a public interest task 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 owner or third parties.

However, it is always possible to request 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 are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.

The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section 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 under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or requesting information from the Data Controller by contacting him at the details indicated at the beginning.

 

Retention period

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 related to the legitimate interest of the Owner will be retained until this 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 Data Controller can keep the Personal Data longer until such consent is revoked. In addition, 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, Personal Data will be deleted. Therefore, at the end 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

 

User data are collected to allow the owner to provide the service, fulfill legal obligations, respond to requests or executive actions, protect their rights and interests (or those of users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Access to accounts on third party services, Optimization and distribution of traffic, Management of contacts and sending of messages and Registration and authentication provided directly from this site / platform.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the “Detailed information on the processing of Personal Data” section.

 

Details on the processing of personal data

 

Personal data are collected for the following purposes and using the following services:

  • Access to accounts on third party services

This type of service allows this site / platform to collect data from your accounts on third party services and These services are not activated automatically, but require the express authorization of the User.

Stripe Account Access (Stripe Inc)

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

Personal data processed: various types of data as specified in the privacy policy of the service.

Place of treatment: United States – Privacy Policy. Subject adhering to the Privacy Shield.

 

  • Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.

Google could use Personal Data to contextualize and personalize the advertisements of its advertising network.

Personal Data processed: Cookies; Usage data.

Place of treatment: United States – Privacy Policy – Opt Out. Person adhering to the Privacy Shield.

 

  • Advertising

We also use third parties (such as LinkedIn, Google AdRoll, YouTube) to serve advertisements that may be of interest to you on other websites. For more information and the ability to control your preferences, please visit:

https://policies.google.com/privacy/partners
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
https://account.microsoft.com/privacy/ad-settings/signedout
https://adssettings.google.com/authenticated
https://www.facebook.com/ads/preferences/

Personal Data processed: Cookies; Usage data.

Place of treatment: see single links above

 

Contact management and sending messages

This type of service allows you to manage a database of e-mail contacts, telephone contacts or contacts of any other type, used to communicate with the User.

These services could also allow you to collect data relating to the date and time of display of the messages by the User, as well as the interaction of the User with them, such as information on clicks on the links inserted in the messages.

 

Mailchimp (The Rocket Science Group LLC)

Mailchimp is an address management and emailing service provided by The Rocket Science Group LLC.

Personal Data processed: surname, name, username, e-mail.

Place of treatment: United States – Privacy Policy. Subject adhering to the Privacy Shield.

 

  • Optimization and distribution of traffic

This type of service allows this site / platform to distribute its content through servers located throughout the territory and to optimize its performance.

The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter the communications between this site / platform and the User’s browser.

Given the distributed nature of this system, it is difficult to determine the places where the contents are transferred, which could contain the User’s Personal Data.

 

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

The Cloudflare integration methods provide that this filters all traffic from this site / platform, i.e. communications between this site / platform and the User’s browser, also allowing the collection of statistical data on it.

Personal Data processed: Cookies; various types of data as specified in the privacy policy of the service.

Place of treatment: United States – Privacy Policy.

 

  • Registration and authentication provided directly from this site / platform

By registering or authenticating, the User allows this site / platform to identify him and to give him access to dedicated services. Personal Data is collected and stored exclusively for registration or identification purposes. The data collected are only those necessary to provide the service requested by the User.

 

Direct registration (this site / platform)

The User registers by filling in the registration form and providing his Personal Data directly to this site / platform.

Personal Data processed: surname, name, username, e-mail, password.

  • Display of 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 to interact with them.

This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

 

Awesome Font (Fonticons, Inc.)

Font Awesome is a font style visualization service managed by Fonticons, Inc. that allows this Application to integrate such content within its pages.

Personal Data processed: Usage data.

Place of treatment: United States – Privacy Policy.

 

Google Fonts (Google LLC)

Google Fonts is a font style visualization service managed by Google LLC that allows this Application to integrate such content within its pages.

Personal Data processed: Usage data; various types of data as specified in the privacy policy of the service.

Place of treatment: United States – Privacy Policy. Subject adhering to the Privacy Shield.

 

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 withdraw consent to the processing of their Personal Data previously expressed.
  • object to 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. Further details on the right to object are indicated in the section below.
  • access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
  • verify and request correction. 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 other than their conservation.
  • obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
  • receive your data or have it transferred to another holder. 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 treatment 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 control authority or take legal action.

 

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public powers with which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.

Users are reminded that, if their data were processed for direct marketing purposes, they can oppose the processing without giving any reasons. 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 rights of the User, 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 the treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this site / platform or related Services by the User.

The User declares to be aware that the Data Controller 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 site / platform may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this site / platform 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 to the Data Controller using the contact details.

Reply to “Do Not Track” requests

This site / platform does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult their 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 notifying it to Users on this page and, if possible, on this site / platform as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details you have. Please therefore consult this page frequently, 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)

It constitutes personal data 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

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

User

The individual who uses this site / platform which, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Responsible)

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

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this site / platform. The Data Controller, unless otherwise specified, is the owner of this site / platform.

This site / platform

The hardware or software tool through which Users’ Personal Data is collected and processed.

Service

The service provided by this site / platform as defined in the relative terms (if any) on this site / application.

European Union (or EU)

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

Cookie

Small portion of data stored 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 only concerns this site / platform.

Last modified: February 27, 2020