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Data Controller

ART srl, Via Francesco Petrarca 9, Azzano San Paolo 24052, BG

Owner’s email address: info@aerreti.it

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: email; password; Tracking Tool; Usage data; Data communicated during use of the service; device information; purchase history; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); various types of Data; first name; surname; Billing information; Universally unique identifier (UUID).
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, as well as to the additional purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees that he or she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

Method and place of processing of collected data

Treatment methods
The Data Controller adopts 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 Owner, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of 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 Owner may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to this 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 the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Place
The Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

Shelf life
The Data is processed and stored for the time required by the purposes for which it was 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 Owner will be retained until such 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 User’s consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement 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: Contacting the User, Registration and authentication provided directly by this Website, Access to accounts on third party services, Statistics, Viewing content from external platforms, Managing contacts and sending messages, Managing requests support and contact, Hosting and backend infrastructure, Remarketing and behavioral targeting, Infrastructure monitoring, Payment management, Commercial affiliation, Tag management, Interaction with social networks and external platforms, Data transfer outside the EU, Interaction with live chat platforms, User database management, Interaction with data collection platforms and other third parties, Advertising, Registration and authentication, Management of web conferences and online telephony, Content and functionality performance testing (A/B testing) , Information Gathering and Data Linking.

Facebook permissions required by this Website

This Website may ask for certain Facebook permissions that allow it to perform actions with the User’s Facebook account and collect information, including Personal Data, from it. This service allows this Website to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information on the following permissions, refer to the Facebook permissions documentation and Facebook’s 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 localization language and, in some cases, Facebook “Friends”. If the User has made additional Data publicly available, the same will be available.
Email
Provides access to the User’s primary email address.

Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Registration and authentication provided directly by this website
By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services. Personal Data is collected and stored exclusively for registration or identification purposes. The Data collected is only that necessary to provide the service requested by the User.
Direct Registration (this Website)
The User registers by completing the registration form and providing his/her Personal Data directly to this Website.
Personal Data processed: email; password.
Legal basis for processing: Consent.
Legal basis for transferring Data outside the EU: No data transfer.

Statistics

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

Google Ads conversion tracking
Google Ads conversion tracking is a statistics service provided by Google LLC or by Google Ireland Limited, depending on the location in which this Website is used, which connects data from the Google Ads advertising network with actions performed on the website. inside this Website.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

Google Analytics with anonymized IP
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
This Google Analytics integration anonymizes your IP address. Anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google servers and shortened within the United States.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

Twitter Ads conversion tracking (Twitter, Inc.)
Twitter Ads conversion tracking is a statistics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.

User ID extension for Google Analytics
Google Analytics on this Website uses a feature called User ID. This allows for more accurate tracking of Users by assigning each 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 Data relating to the user collected by this Website.
Personal Data processed: Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

Facebook Ads Conversion Tracking (Facebook Pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed within this Website. The Facebook pixel monitors conversions conversions that can be attributed to Facebook, Instagram and Audience Network ads.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

Advertising reporting features in Google Analytics
Google Analytics on this Website has enabled advertising reporting features, which collect additional information from the DoubleClick cookie (web activity) and device advertising IDs (application activity). This allows the Owner to analyze specific Data relating to Users’ behaviors and interests (Traffic Data and Users’ interaction data with ads) and, if enabled, Demographic Data (information on age and gender).

Users can choose not to use Google cookies by visiting Google’s [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tool; various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

Google Analytics Demographics and Interests Reports
Google Analytics Demographics and Interest Reporting is an advertising reporting feature that makes Demographic and Interest Data available within Google Analytics for this Website (Demographic Data means age and gender Data ).

Users can choose not to use Google cookies by visiting Google’s [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States – Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.

LinkedIn Conversion Tracking (LinkedIn Corporation)
LinkedIn conversion tracking is a statistics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website.
Personal Data processed: Usage data; device information; Tracking Tool.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: Data retention for the time necessary to achieve the purpose.

Contact the User

Mailing List or Newsletter (this Website)
By registering on the mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information, including commercial and promotional information, relating to this Website may be sent. The User’s email address may also be added to this list as a result of registering on this Website or after making a purchase.
Personal Data processed: email.
Legal basis for processing: Consent.

Tag management
This type of service is functional to the centralized management of tags or scripts used on this Website.
The use of these services involves the flow of User Data through them and, if applicable, their retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage data.
Place of processing: Ireland.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: 18 months.

Interactions with social networks
This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User’s privacy settings relating to each social network.
This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out of the respective services to ensure that the data processed on this Website is not linked to the User’s profile.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services for interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.

Facebook Like button and social widgets (Facebook, Inc.)
The “Like” button and Facebook social widgets are interaction services with the Facebook social network, provided by Facebook, Inc.
Personal Data processed: Usage data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transferring Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data retention period: 3 months.

Registration and Authentication
By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services.
Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. If this happens, this Website may access some Data stored by the third-party service used for registration or identification.
Some of the services indicated below may also collect Personal Data for targeting and profiling purposes; To find out more, please refer to the description of each service.

Hosting and infrastructure
This type of service has the function of hosting Data and files that allow this Website to function, allow its distribution and provide a ready-to-use infrastructure to provide specific functions of this Website.
Some services listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

The infrastructure is located in France and is provided by the company:

OVH Srl (Single Member) Share Capital €. 10,000.00 i.v.
Tax code and VAT number 06157670966 Milan Company Register no. 06157670966
REA n° 1873458.
Registered office: Via Carlo Imbonati, 18 20159 Milan

User Rights
Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:

• revoke your consent at any time. The User may revoke the previously expressed consent to the processing of their Personal Data.
• oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
• access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
• check and request rectification. The User can verify the correctness of their Data and request its updating or correction.
• obtain the limitation of treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Owner will not process the Data for any purpose other than their conservation.
• obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.
• receive your Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its 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 of which the User is a party or on contractual measures connected to it.
• submit a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Owner processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights
To exercise the User’s rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as quickly as possible, in any case within one month.

Further information on treatment

Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible 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 reveal the Data by order of public authorities.

Specific information
Upon 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 and maintenance logs
For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, i.e. files that record 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 whether 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 Data Controller. Please therefore consult this page regularly, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Owner will collect the User’s consent again, if necessary.

Definitions and legal references
Personal Data (or 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 constitutes personal data.

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

User
The individual who uses this Application who, unless otherwise specified, coincides with the interested party.

Interested
The natural person to whom the Personal Data 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 Data Controller)
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 and the tools adopted, including 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 is 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 include all current member states of the European Union and the European Economic Area.

Cookies
Small portion of data stored within the User’s device.

Legal references
This privacy information is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.