Data Controller

Alessandro Panza – viale spartaco 67 -00174 Rome

Email address: digitalpanza@gmail.com

Types of collected data

Among the Personal Data collected by this Website, independently or through third parties, are email addresses.

Users who have doubts about which data are mandatory are encouraged to contact the Data Controller.
The use of cookies – or other tracking tools – by this Website or by the third-party service providers used by this website, unless otherwise specified, is aimed at providing the best possible service requested by the User, as well as for other purposes described in this document and in the Cookie Policy, if available.

The User takes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disclose them, releasing the Data Controller from any liability to third parties.

Methods and location of data processing

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller.

Legal basis for 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 legal basis specified below, as long as the User does not object (“opt-out”) to such processing. 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 performance of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary to comply with a legal obligation to which the Data Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is always possible to ask the Data Controller to clarify the specific 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.

Location

The Data is processed at the Data Controller’s operational headquarters and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller. 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 location of the processing, the User can contact the Data Controller by email.

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, and about the security measures taken by the Data Controller to protect the Data.

Data retention period

The Data is processed and stored for the time required for 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 such contract is fully executed.
• Personal Data collected for purposes related to the legitimate interests of the Owner will be retained until such interests are fulfilled. The User can find further information regarding the Owner’s legitimate interests in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User’s consent, the Owner may retain Personal Data for a longer period until such consent is revoked. In addition, 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, Personal Data will be deleted. Therefore, upon expiration of this period, the right to access, delete, rectify, and the right to data portability can no longer be exercised.

Purposes of processing of collected data

User Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), detect any fraudulent or malicious activities, as well as for the following purposes: Contact management and sending of messages and Contacting the User.

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can send an email to the Owner.

Details on the Processing of Personal Data

Contact Form (this Website)

By filling in the contact form with their data, the User consents to their use to respond to requests for information, quotes, or any other kind of request indicated by the form’s header.

Processed Personal Data: email.

Category of Personal Information collected under CCPA: identifiers.

Management of Contacts and Sending of Messages

This type of service allows for the management of a database of email contacts, phone contacts, or contacts of any other kind, used to communicate with the User.
These services may also allow for the collection of data related to the date and time of the User’s message viewing, as well as the User’s interaction with them, such as information on clicks on the links inserted in the messages.

Mailchimp (The Rocket Science Group LLC)

Mailchimp is a service for managing addresses and sending email messages provided by The Rocket Science Group LLC.

Processed Personal Data: email.

Location of processing: United States – Privacy Policy.

Category of Personal Information collected under CCPA: identifiers.

User Rights

Users have certain rights with regard to the Data processed by the Owner.

In particular, the User has the right to:

• withdraw consent at any time. The User may revoke the consent previously expressed for the processing of their Personal Data.
• object to processing of their Data. The User may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their Data. The User has the right to obtain information about 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 may verify the accuracy of their Data and request its updating or correction.
• obtain the limitation of processing. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Owner will not process the Data for any purpose other than its storage.
• obtain the erasure or removal of their Personal Data. When certain conditions are met, the User may request the erasure of their Data by the Owner.
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format, and, where technically feasible, to have it transferred to another controller without hindrance. This provision applies when the Data is processed by automated means 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.
• lodge a complaint. The User may lodge a complaint with the competent supervisory authority for the protection of personal data 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 for the pursuit of a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are hereby informed that, where their Data is processed for direct marketing purposes, they may object to the processing without providing any justification. To find out if the Owner processes data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise your rights

To exercise their rights, Users may make a request to the contact details of the Owner indicated in this document. Requests are free of charge and processed by the Owner as soon as possible, in any case within one month.

Further information on processing

Defense in court

The User’s Personal Data may be used by the Owner in court or in the stages leading to its possible establishment for the defense against abuse in the use of this Website or related Services by the User.
The User declares to be aware that the Owner may be required to disclose the Data by public authorities.

Specific information

On request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning specific Services or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, this website and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not included in this policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Response to “Do Not Track” requests

This website does not support “Do Not Track” requests. To find out if any third-party services used support them, Users are encouraged to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this website, and, if technically and legally feasible, by sending a notification to Users through one of the contact details available. Therefore, please check this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes affect processing that is based on consent as its legal basis, the Data Controller will collect the User’s consent again, if necessary.

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Information for California consumers

This section of the document supplements and complements the information contained in the rest of the privacy policy and is provided by the operator of this website and, where applicable, by its company, parent company, and subsidiaries and affiliates (collectively referred to as “we”, “our” or “us” for the purposes of this section).

The provisions contained in this section apply to all Users who are considered consumers residing in the state of California, United States of America, pursuant to the “California Consumer Privacy Act of 2018” (such Users are referred to herein simply as “you”, “your”, “yours” or “yourself”), and for such individuals, these provisions supersede any conflicting or divergent provisions contained in this privacy policy.

In this section of the document, the term “personal information” is used as defined by the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed, or sold

This section summarizes the categories of personal information we have collected, disclosed, or “sold” pursuant to the CCPA and the related purposes of processing. Detailed information about these activities can be found in the section entitled “Details on the processing of Personal Data” in this document.

Information we collect: categories of personal information we collect

We have collected the following categories of personal information about you: identifiers.

We will not collect any additional categories of personal information without first providing you with a new notice.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information directly or indirectly from you when you use this website.

For example, you provide us with your personal information directly when you submit requests through any form on this website. Additionally, you indirectly provide us with personal information when you browse this website, as the personal information concerning you is automatically observed and collected. Finally, we may collect your personal information from third parties working with us in relation to the provision of the Service or the operation of this website and its features.

How we use the information we collect: sharing and communication of your personal information with third parties for operational purposes.

We may share your personal information with third parties for operational and service purposes. In this case, we enter into a written contract with such third party that obligates the recipient of your personal information to keep such information confidential and not use it for purposes other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you request it or authorize us to do so in order to provide you with our Service.

For further information on the purposes of the processing, please refer to the relevant section of this document.

No sale of your personal information

We have not sold any of your personal information in the last 24 months.

What are the purposes for which we use your personal information?

We may use your personal information to enable the proper functioning of this website and its features (“operational purposes”). In such cases, your personal information will be processed appropriately and proportionally to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the “Details on Personal Data Processing” section within this document), as well as to comply with the law and defend our rights before competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for purposes that are different, unrelated, or incompatible without first notifying you.

Your Privacy Rights in California and How to Exercise Them

Right to Know and Portability

You have the right to know the following:

• The categories of personal information we collect about you and the sources of such information, the purposes for which we use your personal information, and with whom we share it;
• In case of sale or disclosure of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will communicate:
  • for the sale, the categories of personal information disclosed to each category of recipient; and
  • for disclosure to third parties for operational purposes, the categories of personal information obtained from each category of recipient;

The above information will be limited to personal information collected or used in the last 12 months.
If our response is provided electronically, the information contained therein will be “portable,” that is, delivered in a compatible format so as to allow you to transmit the information to other entities without hindrance – provided that this is technically feasible.

Right to request deletion of personal information

You have the right to request the deletion of any of your personal information, subject to exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors on this website, to detect security incidents, for fraud or illegal activity prevention purposes, to exercise certain rights, etc.).

If no exceptions provided by law apply, upon exercising your right, we will delete your personal information and instruct our providers to do the same.

How to exercise your rights

To exercise the aforementioned rights, you need to submit a verifiable request by contacting us through the details provided in this document.

To respond to your request, we need to be able to identify you. For this reason, you can exercise the aforementioned rights only by submitting a verifiable request that must:

• provide sufficient information to reasonably verify that you are the person to whom the collected personal information pertains or an authorized representative;
• describe your request with a level of detail sufficient for us to understand, evaluate, and correctly respond to it.

We will not respond to any request if we cannot verify your identity and, therefore, confirm that the information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can delegate a person registered with the California Secretary of State to do it on your behalf.

If you are an adult, you can submit a verifiable request on behalf of someone who is under your parental authority.

You can submit a maximum of 2 requests within 12 months.

How and when we will handle your request

Within 10 days, we will confirm that we have received your request and provide you with information on how we will process it.

We will respond to your request within 45 days of receiving it. If we need more time, we will explain why and tell you how much time we need. Please note that we may take up to 90 days to fulfill your request.

Our communications will cover the preceding 12-month period.

If we deny your request, we will explain the reason for the refusal.

We will not charge a fee for processing or responding to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may apply a reasonable fee or deny the request. In either case, we will communicate our decisions and explain the reasons for them.

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Information for Users residing in Brazil

This section of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this website and, if applicable, by its parent company and its subsidiaries and affiliates (collectively referred to in this section as “we,” “our,” or “us”). The provisions contained in this section apply to all Users who are residents in Brazil, pursuant to the “Lei Geral de Proteção de Dados” (such Users are referred to herein simply as “you,” “your,” or “yours”). For such Users, these provisions prevail over any other provision that may be divergent or in conflict contained in this privacy policy. In this section of the document, the term “personal information” is used as defined by the “Lei Geral de Proteção de Dados” (LGPD).

Legal bases for the processing of your personal information

We process your personal information only if one of the legal bases for such processing exists. The legal bases are as follows:

• your consent to the processing activities in question;
• compliance with legal obligations that we are required to fulfill;
• the execution of rules dictated by laws or regulations or by contracts, agreements, or other similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the execution of a contract and the related pre-contractual obligations, if you are a party to such contract;
• the exercise of our rights in court, in administrative proceedings, or in arbitrations;
• the defense or physical safety of you or a third party;
• the protection of health – in the context of procedures implemented by entities or professionals in the healthcare sector;
• our legitimate interest, provided that your fundamental rights and freedoms do not prevail over such interests; and
• the protection of credit.
• To learn more about legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To learn about the categories of personal information processed, you can refer to the “Details on Personal Data Processing” section in this document.

Why we process your personal information

To learn why we process your personal information, please refer to the “Details on Personal Data Processing” and “Purposes of Data Processing” sections in this document.

Your privacy rights in Brazil, how to make a request, and how we will handle it

Your privacy rights in Brazil

• obtain confirmation of the existence of processing activities regarding your personal information;
• access your personal information;
• obtain the rectification of your incomplete, inaccurate, or not updated personal information;
• obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is processed in breach of the provisions of the LGPD;
• obtain information regarding the possibility of providing or refusing your consent and the related consequences;
• obtain information regarding the third parties with whom we share your personal information;
• obtain, upon your explicit request, the portability of your personal information (excluding anonymized information) to other product or service providers, provided that our trade and industrial secrets are safeguarded;
• obtain the deletion of personal information processed if the processing was carried out based on your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply;
• revoke your consent at any time;
• file a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection agency;
• object to processing activities in cases where such processing is not carried out in accordance with legal provisions;
• request clear and adequate information regarding the criteria and procedures used in automated decision-making processes; and
• request the review of decisions that affect your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to profile your personal, professional, consumer, or creditor profile, or other aspects of your personality.

You will never be discriminated against or otherwise disadvantaged as a result of exercising your rights.

How to make a request

You can make an explicit request to exercise your rights free of charge at any time using the contact details in this document or through your legal representative

How we will handle your request and provide you with information

We will do our best to respond to your request as quickly as possible. However, if it is not possible for us to do so, we will ensure that we communicate the factual or legal reasons that prevent us from immediately fulfilling or responding to your request. If your personal information is not processed by us, we will, if possible, indicate the natural or legal person to whom you should address your requests.

If you decide to submit a request for access or confirmation of the processing of personal information, please specify whether you prefer to receive your personal information in electronic or paper format. Additionally, let us know if you require an immediate response. If so, you will receive a simplified response. Otherwise, if you need comprehensive information, we will respond within 15 days from the date of your request, providing you with all the information regarding the origin of your personal information, confirmation of the existence of personal information concerning you, the criteria used for processing, and the purposes of such processing while safeguarding our trade secrets and industrial secrets.

If you decide to submit a request for rectification, deletion, anonymization, or blocking of personal information, we will immediately inform the other parties with whom we have shared your personal information so that they can also fulfill your request, except in cases where such communication is impossible or excessively onerous for us.

Transfer of personal information outside of Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

• When the transfer is necessary for international legal cooperation among intelligence services, investigative and criminal procedure bodies, as provided for by the instruments made available by international law.
• When the transfer is necessary to defend your life or physical safety or that of third parties.
• When the transfer is authorized by ANPD.
• When the transfer arises from an obligation assumed in the context of an international cooperation agreement.
• When the transfer is necessary for the exercise of public order or the performance of a public service.
• When the transfer is necessary for compliance with a legal obligation, the execution of a contract and its pre-contractual obligations, or the normal exercise of rights in judicial, administrative, or arbitral proceedings.

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Definitions and Legal References

Personal Data

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

Usage Data

Information that is automatically collected through this Application (including from third-party applications integrated into this Site), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Site, 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 visitor, the various time details per visit (e.g., the time spent on each page within the Site) and the details about the path followed within the Site with special reference to the sequence of pages visited, and other parameters about the operating system and the user’s IT environment.

User

The individual who uses this Site, unless otherwise specified, is 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 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, including the security measures concerning the operation and use of this Site. The Data Controller, unless otherwise specified, is the owner of this Site.

This Site

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

Service

The service provided by this Site as described 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 shall be extended to all current member states of the European Union and the European Economic Area.

Legal References

This privacy statement is drafted based on multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement only concerns this Site.

Last modified 03/21/2023