Back to top
Share

Privacy Policy

Because we care about the protection of your personal data

1. Types of Data Collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address, name, Cookies and Usage Data.

Complete details on each type of Personal Data collected are provided in the relevant 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 such Data may make it impossible for this Website to provide its Service. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate such 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 employed by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in this Privacy Policy and the Cookie Policy which forms an integral part hereof.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

 

2. Mode and Place of Processing the Data

Data is processed in the following ways:

 

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processor by the Owner. The updated list of such 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;
  • 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; or
  • 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 relevant sections of this Privacy Policy containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the United Nations, 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 Privacy Policy or inquire with the Owner using the contact information provided on this Website.

 

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 fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Privacy Policy 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.

 

3. Purpose of Processing Data

The Data concerning the User is collected to allow the Owner to provide its Service, as well as for the purposes outlined in the relevant sections of this Privacy Policy, where Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose.

 

4. Detailed Information on the Processing of Personal Data

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

 

Contacting the User

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 such list as a result of signing up to this Website or after making a purchase.

Personal Data collected: email address and name.

By filling in the contact form with their Data, the User authorises this Website to use such details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: email address and name.

 

Managing Contacts and Sending Messages

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

Personal Data collected: name and email address.

Place of processing: USA

The privacy policy of MailChimp can be found under https://mailchimp.com/legal/privacy/.

 

Displaying Content from External Platforms

Such type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. Such 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 is a maps visualisation service provided by Google Inc. that allows this Website to incorporate content of such kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA

The privacy policy of Google Maps can be found under https://policies.google.com/privacy?hl=en&gl=it.

 

Platform Services and Hosting

Such services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – for instance, analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of the services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Website.

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

Place of processing: USA

The privacy policy of WordPress.com can be found under https://automattic.com/privacy/.

 

SPAM Protection

Such type of service analyses the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

Akismet is a SPAM protection service provided by Automattic Inc.

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

Place of processing: USA

The privacy policy of Akismet can be found under https://automattic.com/privacy/.

 

Backup Saving and Management

Such type of service allows the Owner to save and manage backups of this Website 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 Website.

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

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

Place of processing: USA

The privacy policy of Dropbox can be found under https://www.dropbox.com/privacy#privacy.

 

5. 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);
  • 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 which 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; 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); and
  • 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, however, that 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 Privacy Policy.

 

How to Exercise such Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided on this Website. Such requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

6. Cookie Policy

This Website employs Cookies. Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User’s consent. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this Privacy Policy.

 

Technical Cookies and Cookies Serving Aggregated Statistical Purposes

This Website employs Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of this Website, for example in relation to the distribution of traffic. This Website employs Cookies to save browsing preferences and to optimise the User’s browsing experience. Among such Cookies are, for example, those employed for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.

 

Other Types of Cookies or Third Parties that Install Cookies

Some of the services used by this Website collect statistics in an anonymised and aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties. In addition, such employed services may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policies of the services employed by this Website.

 

How to Provide or Withdraw Consent to the Installation of Cookies

In addition to what is specified in this Privacy Policy, Users can manage preferences for Cookies directly from within their own browser and prevent third parties from installing Cookies. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this Website. Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Apple Safari: https://support.apple.com/kb/PH19214?viewlocale=en_US&locale=en_US

Microsoft Windows Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party’s privacy policy or by contacting the third party.

Notwithstanding the remarks in this Privacy Policy, the Owner informs that Users may follow the instructions provided on the following services:

European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu

Network Advertising Initiative: https://www.networkadvertising.org/understanding-digital-advertising

Digital Advertising Alliance: https://www.aboutads.info/consumers

Digital Advertising Alliance of Canada: https://youradchoices.ca/understanding-online-advertising

Data Driven Advertising Initiative: http://www.ddai.info/optout

Such services allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of such or other similar resources in addition to the information provided in this Privacy Policy.

 

Owner and Data Control

Since the installation of third-party Cookies and other tracking systems through the services used within this Website cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, User are encouraged to consult the privacy policy for the respective third-party services listed in this Privacy Policy.

Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by this Website.

 

7. Additional Information about Data Collection and Processing

The following additional information is important to note in the context of this Privacy Policy:

 

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 Service. 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 a particular Service 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 such purpose.

 

Information Not Contained in this Privacy 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 provided on this Website.

 

How “Do not Track” Requests are Handled

This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour 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 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 Privacy Policy 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.

 

8. Definitions and Legal References

The following definitions and legal references apply to this Privacy Policy:

 

Cookies

Small sets of data stored in the User’s device.

 

Data or Personal Data

Any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.

 

Data Processor

The natural or legal person, public authority, agency or other body, which processes Personal Data on behalf of the Owner, as described in this Privacy Policy.

 

Data Subject

The natural person to whom the Personal Data refers.

 

European Union

Unless otherwise specified, all current member states of the European Union and the European Economic Area.

 

Owner

VABY Limited.

 

Service

The information service provided by this Website.

 

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 utilised by the Users who use this Website, the URI (Uniform Resource Identifier) addresses, the time of the request, the method utilised 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 utilised by the User, the various time details per visit (e.g., the time spent on each page on this Website) and the details about the path followed on this Website 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.

 

Website

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

 

9. Legal Information

This Privacy Policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This Privacy Policy relates solely to this Website, if not stated otherwise herein.

This Privacy Policy has last been updated on 20 March 2020.