Sensory Trust is committed to safeguarding the privacy of your personal data. Please read the following policy to understand how your personal data will be treated as you make full use of our services.
1. Who are ‘We’?
In this policy, the words ‘We’, ‘Us’ or ‘Our’ refer to Sensory Trust and its subsidiary and affiliated companies, including Orange Spiral Limited and any other companies that may be incorporated as part of the Sensory Trust Group of companies. Either of these may be the data controller, data processor or both data controller and data processor of your personal data that We collect from you from time to time.
It's really important to Us that you trust Us with your personal data so We want to make sure that you understand what personal data We hold about you and how We collect, store and process it. We comply with the Data Protection Act 1998 and any other relevant statutory and self-regulation such as the Charities (Protection & Social Investment Act) 2006.
We will use your personal data in the way(s) set out in this policy. If you are not happy with the way that We are using your personal data, please do not provide us with your personal data (We have set out more information on how We collect your personal data below). If you have any questions about this policy, or what We do with your personal data, please contact Us using the contact details below.
You can contact Us about this policy at [email protected] or write to the Information Manager, Sensory Trust, Fig Leaf Building, Eden Project, Bodelva, Cornwall PL24 2SG.
2. What is personal data?
Personal data is information about you that can help Us identify you, such as your name, address, phone number or email address, or more discrete data such as the device type and IP address of any smartphones, tablets or similar mobile devices you own.
There are also special categories of personal data that are treated by law as being particularly sensitive. This may include your racial or ethnic origin, your religious beliefs or information related to your health. We will only ever collect special categories of data where We have your explicit consent to do so, where it is in your vital interests that We do so, or to enable Us to make decisions regarding the services that We provide to you.
3. What personal data do We collect about you?
The nature and the type of personal data We collect will depend on why you are giving it to Us. Developing a fuller understanding of our supporters and service users through your personal data allows Us to make better decisions, fundraise more efficiently and to ensure We provide support to more people with disabilities and long-term health conditions.
We collect personal data about you when you:
- use Our website. We collect information where available including your IP address, operating system and browser type. This information helps us produce anonymised data about our users’ browser behaviours. Our website also uses cookies – for more information please read Our full cookies policy;
- purchase items from Our online shop. We collect information such as your name, contact details, delivery address (if applicable) and your anonymised bank/credit card details;
- interact with Us on Our social media pages (such as Twitter, Facebook, and Instagram). We collect information about you from Twitter and Facebook's sites if the settings on your accounts or the privacy policies of those sites give Us permission to do so. This would include your name, and any direct or private messages sent to Us);
- sign up for Our newsletter. This is administered through MailChimp, a third party whose Privacy Policy can be found here. We collect information such as your name and email address and may audit your ‘click throughs’ on the newsletter emails that we send to you;
- participate in events hosted by Us or if you make a donation to us. We collect information such as your name, contact details and delivery address (if applicable). In some circumstances (e.g. if you were taking part in a project activity) We may also ask you for information related to your health;
- voluntarily provide Us with your personal data whilst completing surveys, signing up for events, completing our contact form or providing feedback. We collect information such as your name, email address, postal address and any additional comments or information you give to Us.
4. What do We use your personal data for?
When processing your personal data, We will only do so in relation to specific purposes and only after giving careful consideration to ensure that your privacy rights are not seriously impacted.
We will process the personal data that you provide to us in the following ways for the purpose of (and on the basis of) our performance of our contractual obligations to you:
- To provide you with the services that you have requested or purchased from Us, such as fulfilling your purchase of a product through Our website;
- To administer Our events that you wish to attend, such as if you attend a dementia-friendly activity club We will need to process your information to deliver the activity, including your medical information to ensure that you are protected on the day;
- To process donations or other payments, to verify financial transactions and to claim Gift Aid on your donation;
- To record any contact with you and provide you with information that is tailored and relevant to you;
- We may occasionally use external information to check the accuracy of the contact details We hold. For example, the Royal Mail Postcode Finder is used if We have an incomplete or inaccurate address;
- From time to time We may use external data sources to create a profile of your interests so that Our communications to you are as appropriate and cost effective as possible;
- With your consent, We will send you occasional information to let you know about the work of the charity, the services We provide, to ask for support, or to send details about fundraising events and activities;
- Sharing your story. If you give your consent to share your experience of Sensory Trust, this may be made public by Us at events, in materials promoting Our charity and fundraising work, or in documents such as Our annual report.
We will only retain such profiles for as long as it is appropriate to do so and will always delete this data responsibly in line with Our data retention procedures.
If you cease to have an active relationship with us or request no further contact, we may retain some basic information to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information.
5. Who do We share your personal data with?
Except where We use third party services to collect information, when you are asked for personal data by Us, you are sharing that information with Us alone, unless We specifically state otherwise below. As explained above, 'Us' includes Sensory Trust, Orange Spiral Limited and other companies that may be incorporated as the part of the Sensory Trust Group of companies. Our group shares various operations and business processes so We need to share data within our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so.
We may also provide your personal data to third parties who may process your data as part of the services they carry out on Our behalf. In order to provide you with the services that you have requested from Us, the following third parties may also need to process your personal data:
- third party product and service providers who We engage on your behalf to provide the products or the services that you have agreed to purchase (such as the purchase or delivery of goods purchased on Our website. This may include, for example, courier companies (such as DPD), Royal Mail;
- any statutory, governmental or regulatory body that requests the personal data and that We are obliged (by law or by regulation) to provide;
- our analytics and search engine providers that assist Us in the improvement and optimisation of Our website. For example, Google Analytics. Read their privacy policy online;
Please be aware that web sites that have links on Our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those web sites.
As Our requirements change, We may need to change the third parties that process your personal data to meet those requirements.
We do not sell or rent your personal data to anyone, We will never provide your personal data to another company or charity for their marketing purposes without your explicit consent.
6. How do We protect your personal data?
We will always do Our best to keep your personal data secure. Steps We take in order to do this include the use of technical controls (such as secure servers, firewalls and network protection), limiting the number of people working for Us who have access to your data and ensuring that they are trained in protecting your personal data.
Where We use external suppliers to process your personal data, We put contracts in place to make sure that they treat it as carefully as We would and use it only in accordance with the instructions that We give to them. Where these suppliers operate outside of the European Economic Area (EEA), We will make sure that the levels of protection provided are at least equal to those required by UK law.
7. Retention of your personal data
We will only retain your personal data for as long as We need to keep it. In considering how long to retain your data we will always take into account factors such as any ongoing obligations We have to You, the nature of Our relationship with You, legal requirements (e.g. in relation to HMRC statutory retention periods) and contractual requirements. We will not keep Your data indefinitely and will always dispose of it carefully when it is no longer necessary for Us to retain it, in line with defined schedules in Our data retention procedures.
8. Your Rights – What are the choices available to you regarding collection, use and distribution of your personal data?
The law gives you a number of rights in relation to your personal data and Our use of it. You have the right:
- to ask Us not to use your personal data for direct marketing purposes;
- to ask to see what personal data We hold about You and to find out about the way that We process the data (and in some circumstances, You can ask Us to provide a copy to a third party);
- to ask Us to correct or update any personal data which is inaccurate;
- to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for Us to continue to process it;
- to ask Us to temporarily stop using your data if You don't believe that We have a right to use it, or to stop Us from using your personal data where there is no good reason for Us to continue to use it; and
- not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
If you are unhappy with the way We have dealt with your personal data or if you have any further questions about how We process and retain personal data please contact Us in the first instance so that We can try to put this right.
If you are still not satisfied, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information on how to do this is available on the ICO website.
9. Changing this policy
We may make changes to this policy from time to time. If We make any significant changes to this policy that impacts the way in which your personal data is treated, We will post the changes on this page or, where We feel that the changes are really significant, We may contact you directly. Changes will apply from the time We post them (either here on Our website or when We contact you). This policy was last changed on 15 April 2020
10. How can you access, update or delete your personal data?
In addition to the click options throughout this policy, You may change or update any or all of the personal data that We hold about you by contacting Sensory Trust’s Information Manager by email to [email protected], by post to Information Manager, Sensory Trust, ESAM 7, Carluddon Business Park, St Austell, Cornwall PL216 8WE, or by telephoning 01726 222900.
Last Updated 12 July 2022
Privacy Policy of www.sensorytrust.org.uk/
This Website collects some Personal Data from its Users.
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Owner and Data Controller
Sensory Trust, ESAM 7, Carluddon Business Park, St Austell. Cornwall. PL26 8WE
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Trackers; Usage Data; email address; first name; last name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
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 Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
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.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimization and distribution, Advertising, Remarketing and behavioral targeting, Analytics, Displaying content from external platforms, Content performance and features testing (A/B testing), Spam and bots protection, Tag management, Heat mapping and session recording, Contacting the User, Managing contacts and sending messages, Infrastructure monitoring and Interaction with data collection platforms and other third parties.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
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 (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, 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.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, 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.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out.
Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out.
User ID extension for Google Analytics (Google LLC)
Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Contacting the User
Mailing list or newsletter
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 Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: email address; first name; last name.
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.
Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
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 Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Heat mapping and session recording
Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Infrastructure monitoring
This type of service allows this Website 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 Website.
StatusCake (TrafficCake Limited)
StatusCake is a monitoring service provided by TrafficCake Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
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.
Mailchimp widget (Intuit Inc.)
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
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.
Postmark (Wildbit LLC)
Postmark is an email address management and message sending service provided by Wildbit LLC.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
MailerLite (UAB "Mailerlite")
MailerLite is an email address management and message sending service provided by UAB "Mailerlite".
Personal Data processed: email address; Usage Data.
Place of processing: Lithuania – Privacy Policy.
Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Facebook Custom Audience (Meta Platforms, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy – Opt out.
Facebook Remarketing (Meta Platforms, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Spam and bots protection
This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Tag management
This type of service helps the Owner to manage the tags or scripts needed on this Website 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 processed: Usage Data.
Place of processing: United States – Privacy Policy.
Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare, Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
cdnjs (Cloudflare, Inc.)
cdnjs is a traffic optimization and distribution service provided by Cloudflare, Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
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.
- 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.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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 fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- 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.
- 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 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 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.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including 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.
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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
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 Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (System logs) or 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.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website 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 Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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 Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website 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.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy relates solely to this Website, if not stated otherwise within this document.
Latest update: February 27, 2026
