Privacy Policy

Pursuant to the European Data Protection Regulation EU-GDPR 2016/679 and DL 101/2018 .

(This Application collects some Personal Data of its Users)

Download the Model for the exercise of rights regarding the protection of personal data.

Data Controller

IN MM ® ELISABETH COURT (SUITE 25) CHURCH STREET  – STRATFORD UPON AVON WARWICKSHIRE – CV37 6HX

Owner contact email: info@inmm.it

Types of data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: email, cookies, usage data, password, name, surname and email.

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 during the use of this Application.

Unless otherwise specified, all the data required by this application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application 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 of other tracking tools – by this Application or by the owners of third party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to further 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 Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Method and place of processing of the collected data

Processing methods

The Owner adopts the appropriate security measures aimed at preventing 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 Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, 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 processing

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 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 processing is necessary for the performance of a task of public interest or for the exercise of public authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

In any case, it is always possible to ask the Owner 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 places 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 that 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 consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening details.

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 attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the consent of the User, the Data Controller can keep the Personal Data longer until such 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, 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 processing the collected data

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Interaction with external social networks and platforms, Registration and authentication, Access to accounts on third party services, Management of payments, Infrastructure monitoring, Interaction with live chat platforms, Remarketing and behavioral targeting, Address management and sending of email messages, Statistics, Display of content from external platforms, Commercial affiliation, Interaction with support and feedback platforms, Management of user databases, Management of support and contact requests and Hosting and backend infrastructure.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Facebook permissions requested by this application

This Application may ask for some Facebook permissions that allow it to perform actions with the User’s Facebook account and to collect information, including Personal Data, from it. This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information on the following permissions, refer to the Facebook permissions documentation and the Facebook privacy policy .

The required permissions 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 language of localization and, in some cases, the “Friends” of Facebook. If the User has made further Data publicly available, they will be available.

E-mail

Provides access to the User’s primary email address.

Page management

It allows the application to retrieve the access_tokens for the Pages and Applications that the user administers.

Insight

Provides access to Insight data for pages, applications and domains the user owns.

Details on the processing of Personal Data

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

  • Access to accounts on third party services
  • This type of services allow this Application to collect data from your accounts on third party services and perform actions with them.
  • These services are not activated automatically, but require the express authorization of the User.
  • ACCESS TO THE TWITTER ACCOUNT (TWITTER, INC.)
  • This service allows this Application to connect with the User’s account on the Twitter social network, provided by Twitter, Inc.
  • Personal Data collected: various types of Data as specified in the privacy policy of the service.
  • Place of processing: USA – Privacy Policy.
  • ACCESS TO FACEBOOK ACCOUNT (THIS APPLICATION)
  • This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
  • Permissions asked: Email, Page Management and Insight.
  • Place of processing: USA – Privacy Policy.
  • Contact the user
  • MAILING LIST OR NEWSLETTER (THIS APPLICATION)
  • 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 Application may be sent. The User’s email address may also be added to this list as a result of registering with this Application or after making a purchase.
  • Personal data collected: email.
  • User database management
  • This type of service allows the Owner to build user profiles starting from an email address, the name or any other information that the User provides to this Application, as well as to track the User’s activities through statistical functions. These Personal Data may also be cross-referenced with publicly available information about the User (such as profiles on social networks) and used to build private profiles that the Owner can view and use to improve this Application.
  • Some of these services may also allow the scheduled sending of messages to the User, such as emails based on specific actions performed on this Application.
  • MANAGEMENT OF SUPPORT AND CONTACT REQUESTS
  • This type of service allows this Application to manage support and contact requests received by email or through other tools, such as the contact form.
  • The Personal Data processed depend on the information provided by the User in the messages and on the tool used for communication (for example the email address).
  • ADDRESS MANAGEMENT AND SENDING OF EMAIL MESSAGES
  • This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
  • These services may also allow the collection of data relating to the date and time the messages are displayed by the User, as well as to the User’s interaction with them, such as information on clicks on links inserted in messages.
  • HOSTING AND BACKEND INFRASTRUCTURE
  • This type of service has the function of hosting data and files that allow this Application to function, allow its distribution and make available a ready-to-use infrastructure to provide specific functions of this Application.
  • Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.
  • Interaction with support and feedback platforms
  • This type of service allows interaction with the support and feedback platforms, managed by third parties, directly from the pages of this Application.
  • In the event that an interaction service with support and feedback platforms is installed, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed.
  • INTERACTION WITH SOCIAL NETWORKS AND EXTERNAL PLATFORMS
  • This type of services allow interaction with social networks or other external platforms directly from the pages of this Application.
  • The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network.
  • In the event that an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.
  • TWEET BUTTON AND TWITTER SOCIAL WIDGETS (TWITTER)
  • The Tweet button and Twitter social widgets are interaction services with the Twitter social network, provided by Twitter Inc.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy.
  • LIKE BUTTON AND FACEBOOK SOCIAL WIDGETS (FACEBOOK, INC.)
  • The “Like” button and Facebook social widgets are interaction services with the Facebook social network, provided by Facebook, Inc.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy.
  • +1 BUTTON AND GOOGLE+ SOCIAL WIDGETS (GOOGLE INC.)
  • The +1 button and Google+ social widgets are interaction services with the Google+ social network, provided by Google Inc.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy.
  • Registration and authentication
  • By registering or authenticating, the User allows the Application 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 application will be able to access some data stored by the third party service used for registration or identification.
  • DIRECT REGISTRATION (THIS APPLICATION)
  • The User registers by filling out the registration form and providing his Personal Data directly to this Application.
  • Personal data collected: email and password.
  • 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 ADWORDS CONVERSION TRACKING (GOOGLE INC.)
  • Google AdWords Conversion Tracking is a statistics service provided by Google Inc. that connects data from the Google AdWords ad network with actions performed within this Application.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy.
  • GOOGLE ANALYTICS WITH ANONYMIZED IP (GOOGLE INC.)
  • Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracing and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
  • Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
  • This Google Analytics integration makes your IP address anonymous. Anonymization works by shortening the IP address of 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, the IP address will be sent to Google’s servers and shortened within the United States.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy– Opt Out .
  • DISPLAY ADVERTISERS EXTENSION FOR GOOGLE ANALYTICS (GOOGLE INC.)
  • Google Analytics on this Application may use Google’s interest-based advertising, third-party audience data and information from the DoubleClick Cookie to extend statistics with demographic data, interests and data on interactions with advertisements.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy– Opt Out .
  • USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE INC.)
  • Google Analytics on this Application uses a function called User ID. This allows a 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 Application.
  • The Opt Out link provided below allows you to disable tracking for the device you are using, but does not exclude further tracking activities carried out by the Owner. To deactivate the latter as well, contact the owner via the contact email address.
  • Personal Data collected: Cookies.
  • Place of processing: USA – Privacy Policy– Opt Out .
  • VIEWING CONTENT FROM EXTERNAL PLATFORMS
  • This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
  • In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.
  • YOUTUBE VIDEO WIDGET (GOOGLE INC.)
  • YouTube is a video content viewing service managed by Google Inc. that allows this Application to integrate such content within its pages.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: USA – Privacy Policy.
  • FURTHER INFORMATION ON PERSONAL DATA
  • Additional rights of users
  • We never and for no reason sell or rent User Data to third parties. The only uses of the Data are those highlighted in this policy. Users are the sole owners of their data and can request its modification or cancellation at any time.

User rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

  • withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.
  • oppose the processing of their data.The user can oppose 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 rectification. The User can verify the correctness of his / her Data and request its updating or correction.
  • obtain the limitation of the treatment. When certain conditions are met, the User may 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 his / her Data by the Owner.
  • receive their data or have them transferred to another owner. The User has the right to receive his / her data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to 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 act in court.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.

Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing 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 one month.

Cookie Policy

This application uses cookies. To learn more and to read the detailed information, the User can consult the Cookie Policy .

Further information on 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 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 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 Application and any third party services used by it may collect System Logs, which are 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 through one of the extremes contact number held by the Owner. Please therefore 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)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

USAGE DATA

This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User connecting with this Application, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding 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.) country of origin, the characteristics of the browser and the 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 the pages consulted, the parameters relating to the operating system and the IT environment of the User.

USER

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

INTERESTED

The natural person to whom the Personal Data refers.

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, 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 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 defined in the relative terms (if available) 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.

COOKIES

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

E-MAIL

Provides access to the User’s primary email address.

LEGAL REFERENCES

This privacy statement is drafted 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 Application.

Last modified: November 26, 2018

IN MM ®  hosts this page and collects the Personal Data strictly necessary for the contents of this page to be available.