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Partership with:

© Created by Federica Di Lorenzo Graphics: Stefania D'angelo Ph: Liliana Ricci

Owner and Data Controller


Lab606 S.r.l.s ., Via dei Monti Tiburtini, 606 00157 ROMA (RM), Italy

Owner contact email: info@lab606roma.com


Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; ZIP/Postal code; city; phone number; gender; date of birth; address; business name; various typology of data; username; geographical location; state; picture; password and unique identifier of advertising devices (i.e., Google Advertiser ID or IDFA identifier).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner, relieving the Owner of any responsibility towards third-parties.


Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.


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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

-provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

-processing is necessary for compliance with a legal obligation to which the Owner is subject;

-processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

-processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.


In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


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. Contact the Owner for further information.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.


Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.


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 fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.


The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to 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.


The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Remarketing and behavioral targeting, Contacting the User, Managing contacts and sending messages, Interactions based on the location, Optimization and distribution of the traffic, Registration and authentication, Comments on the contents, Advertising, Performance test of contents and functionality (A/B testing), Interaction with social networks and external platforms and  Displaying content from external platforms.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.


Detailed information on the processing of Personal Data

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


Comment to the contents

The comments’ services allows the Users to formulate and make public their comments concerning the content of this Application. The Users may be allowed to leave anonymous comments according to the settings decided by the Owner. In the case in which the User provided his/her email address among the released Personal Data, the email address may be used to send notifications of comments concerning the same content. The Users are responsible for the content of their comments.

In case a service for comments provided by third-parties is installed, this type of service might still collect Usage Data relative to the webpages in which the service for comments is installed, even when Users do not use it.

Facebook Comments (Facebook, Inc.)
Facebook Comments is a service provided by Facebook, Inc. that allows the Users to leave their comments and share them within the Facebook platform.

Personal Data collected: Cookies; Usage Data.

Place of processing: USA – Privacy Policy 


Tweet button and Twitter social widget (Twitter, Inc.)

The Tweet button and Twitter social widget are services for the interaction with Twitter social network provided by Twitter, Inc.

Personal Data Collected: Cookie and Usage Data

Place of processing: USA – Privacy Policy - Privacy Shield participant.


Contacting the User

Mailing list or newsletter (This Application)

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 Application. The email address of the User might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data collected: ZIP code, city, first name, last name, Cookie, date of birth, Users data, email address, home address, state, phone number, profession, province, business name, gender.


Contact by phone (This Application)

Users that provided their phone number may be contacted for commercial or promotional purposes concerning this Application as well as for support requests.

Personal Data collected: phone number.


Social functionalities

Invite and suggest friends (this Application)

This Application may use the provided Personal Data to allow Users to invite their friends – for example through the address book, if access to it has been authorized – or to suggest friends and connections within this Application.

Personal Data Collected: various types of Data


Public profile (this Application)

Users may have a public profile viewable by other Users. In addition to the provided Personal Data, this profile may contain the interactions of the User with this Application.

Personal Data Collected: city, first name, date of birth, email, picture, address, state, last name, phone number, geographical location, profession, country, business name, gender and username.


User database manager

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.


Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.


OpenSRS (tucows domains inc)

Personal Data collected: last name, Cookie, date of birth, Users data, email address, home address, state, first name, phone number, profession, gender and other types of data, national ID number, VAT registration number and business name.

Place of processing: Canada- Privacy Policy.


Interaction with external social networks and platforms

This type of service makes possible to interact with external social networks and platforms directly from the webpages of this Application. The interactions and the information acquired by this Application are subjected to the privacy settings of the User relative to each social network.

In case a service of interaction with the social networks is installed, this type of service might still collect Usage Data for the pages where the service is installed, even when Users do not use it.


Facebook “Like” button and social widget (Facebook, Inc.)

Facebook “Like” button and social widget are services for the interaction with Facebook social network provided by Facebook, Inc.

Personal Data Collected: Cookie and Usage Data

Place of processing: USA – Privacy Policy - Privacy Shield participant.


LinkedIn button and social widget (LinkedIn Corporation)

LinkedIn button and social widget are services for the interaction with LinkedIn social network provided by LinkedIn Corporation.

Personal Data Collected: Cookie and Usage Data

Place of processing: USA – Privacy Policy


Tweet button and Twitter social widget (Twitter, Inc.)

The Tweet button and Twitter social widget are services for the interaction with Twitter social network provided by Twitter, Inc.

Personal Data Collected: Cookie and Usage Data

Place of processing: USA – Privacy Policy - Privacy Shield participant.


Interactions based on the location

Geolocation (this Application)

This Application may collect, use and share the Data concerning the geographic location of the User to provide services based on the location.

The majority of the browsers and of the devices provide default settings to deny the tracking of the location.  In case the User explicitly authorized such possibility, this Application may receive information regarding the actual geographic location.

Personal Data Collected: geographic location.


Non-continuous geolocation (this Application)

This Application may collect, use and share the Data concerning the geographic location of the User to provide services based on the location.

The majority of the browsers and of the devices provide default settings to deny the tracking of the location.  In case the User explicitly authorized such possibility, this Application may receive information regarding the actual geographic location.

The geographic localization of the User occurs in a non-continuous way, under explicit request of the User or when the User does not indicate his/her location in the specific field and consents the Application to automatically detect the location.

Personal Data Collected: geographic location.


Optimization and traffic management

This kind of services makes it possible for this Application to distribute its content by means of servers scattered on the territory and to optimize the performances of this Application.

The Personal Data that may be processed depend on the characteristics or modalities of the implementation of these services, that by their nature filter the communication between this Application and the User’s browser.

Given the distributed nature of this system, it is difficult to determine the place where the contents, that may include the User’s Personal Data, may be transferred.


Google Cloud Storage (Google Inc.)
Google Cloud Storage is a hosting service provided by Google Inc.

Personal Data Collected: various types of Data according to what is specified in the privacy policy of the service.

Place of processing: USA – Privacy Policy - Privacy Shield participant.


Advertisement

This type of services makes it possible for this Application to use the Users’ Data for commercial communications in various advertising forms, such as banners, also in relation to the interests of the User. This does not mean that the Personal Data are used for these purposes.

Data and conditions of use are indicated below.

Some of the services indicated below may employ Cookies to identify the User or employ the behavioral retargeting technique that visualize personalized ads based on the interests and behaviors of the Users, which may also be detected outside of this Application. For more information to this regard, we suggest to verify the privacy policy of the various services.


Direct Email Marketing (DEM) (this Application)

This application makes use of the Users’ Personal Data to advertise services and products of third-parties not correlated to the products and services of this Application.

Personal Data Collected: email.


Facebook Audience Network (Facebook, Inc.)

Facebook Audience Network is an advertising service provided by Facebook, Inc. To understand how Facebook makes use of the Data, please refer to Facebook data regulation. To allow the functioning of Facebook Audience Network, this Application may make use of some identifiers for mobile devices (such as Android Advertising ID or Advertising Identifier per OS) as well as technologies similar to Cookies. The use of the advertisement settings of the User is one of the possible ways in which Audience Network proposes advertising messages. The User can check on the sharing of his/her advertisement settings in the Facebook Ad settings. The User may opt-out from Audience Network targeting functions by checking on the settings on his/her device. For example, Users may modify the advertisement settings available on their mobile devices or they may follow the instructions applicable to Audience Network, possibly included in this privacy policy.

Personal Data Collected: Cookie, Usage Data and univocal identifier of devices for advertising (for example, Google Advertiser ID or IDFA identifier).

Place of processing: US – Privacy Policy - – Opt Out - Privacy Shield participant.


Registration and authentication

By means of the registration or authentication, the User consents to be identified by this Application and gives it access to the dedicated services.

According to what is indicated below, the services of registration and authentication may be provided with the aid of third-parties. In this case, this Application may access certain Data stored in the third-party service used for the registration or identification.


Facebook Authentication (Facebook, Inc.)

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and linked to Facebook social network.

Personal Data Collected: various types of Data according to what is specified in the privacy policy of the service.

Place of processing: USA – Privacy Policy.


Twitter OAuth (Twitter, Inc.)

Twitter Oauth is a registration and authentication service provided by Twitter, Inc and linked to Twitter social network..

Personal Data Collected: various types of Data according to what is specified in the privacy policy of the service.

Place of processing: USA – Privacy Policy - Privacy Shield participant.


Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.


Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies; email address.

Place of processing: USA– Privacy Policy – Opt Out.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies; email address.

Place of processing: USA– Privacy Policy – Opt Out.


Remarketing with Google Analytics for display advertisement (Google Inc.)

Remarketing with Google Analytics for the display advertisement is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.


Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.


Analytics collected directly within this Application

This Application employs an internal analytics system that does not involve third-parties.

Personal Data Collected: Cookies; Usage Data


Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant.



Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy. Privacy Shield participant.


ShinyStat (Triboo Data Analytics S.R.L.)
ShynyStat (ShynyStat Business, ShynyStat Pro or ShinyStat ISP) is an analytics service provided by Triboo Data Analytics S.R.L.
This analytics service anonymizes the IP address of the User.

Personal Data collected: Cookies; Usage Data.

Place of processing: Italy – Privacy Policy – Opt Out..

ShinyStat  Free (Triboo Data Analytics S.R.L.)
ShynyStat is an analytics service provided by Triboo Data Analytics S.R.L.
This analytics service anonymizes the IP address of the User.

Personal Data collected: Cookies; Usage Data.

Place of processing: Italy – Privacy Policy – Opt Out..           


Performance Test of the contents and functionalities (A/B testing)

The services contained in this section allow the Owner and Controller to keep track and analyze the response of the Users in terms of traffic or behavior in relation to modifications in the structure, in the text or in any other component of this Application.


Google Website Optimizer (Google Inc.)

Google Website Optimizer is an A/B testing service provided by Google Inc. ("Google").
Google may make use of Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data Collected: Cookie and Usage Data

Place of processing: USA – Privacy Policy - Privacy Shield participant

Google Maps widget (Google Inc.)
Google Maps is a map viewing service managed by Google Inc. that allows this Application to integrate content within its pages.
Personal data collected: Cookies and usage data.
Place of processing: United States - Privacy Policy. Subject adherent to the Privacy Shield.


Instagram widget (Instagram, Inc.)

Instagram is an image viewing service managed by Instagram, Inc. that allows this Application to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States - Privacy Policy.


The 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. Further details are provided in the dedicated section below.

- 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 this case, the Owner will not process their Data for any purpose other than storing it.

- Have their Personal Data deleted or otherwise removed. Users have the right, 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. This provision is applicable 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.

- 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 that, however, 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 document.


​How to exercise these rights

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


​Cookie Policy

This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.


Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.


Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor 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 page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. 

Should the changes affect processing activities performed on the basis of the User’s

consent, the Owner shall collect new consent from the User, where required.


Latest edit: 1 February 2019


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