Privacy Policy

Data Controller

Luigi Marino / Creact SRL - Viale Traiano, 339 - 80126 Napoli

Holder's email address: [email protected]

Types of Data Collected

Among the Personal Data collected by this Web Site, either independently or through third parties, are: Cookies; Usage Data; first name; last name; email; phone; company; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site are mandatory. If the User refuses to communicate them, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates certain 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 are in doubt about which Data are mandatory are encouraged to contact the Data Controller.
Any use of Cookies - or other tracking tools - by this Website or the owners of third party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the additional purposes described herein and in the Cookie Policy, if available.

The User assumes responsibility for third party Personal Data obtained, published or shared through this Web Site and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

Method and place of processing of collected Data
Mode of treatment

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

Legal basis for processing

The Owner processes Personal Data related 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 need for the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
processing is necessary for the performance 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 Controller is subject;
the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.

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

Location

The Data are processed at the Holder's operational offices and at any other location where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User's Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the processing location, the User may refer to the section on Personal Data processing details.

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 under public international law or formed by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.

Retention period

Data are processed and kept for the time required by the purposes for which they were collected.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User's consent, the Controller may retain Personal Data longer until that consent is revoked. In addition, the Controller may be required 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, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Processing of Collected Data

User Data is collected to enable the Data Controller to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Statistics, Contacting the User, Remarketing and behavioral targeting, Advertising, Heat mapping and session logging, Protection from SPAM and Displaying content from external platforms.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section "Detailed Information on the Processing of Personal Data."
Details of the processing of Personal Data

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

Contact User
Contact Form (this Website)

By filling out the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.

Personal Data Collected: last name; email; first name; phone; company.

Heat mapping and session recording

Heat mapping services are used to identify which areas of a page are subject to cursor hovering or mouse clicks so as to detect which of them attract the most interest. These services make it possible to monitor and analyze traffic data and are used to track User behavior.
Some of these services may record sessions and make them available for viewing later.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct the script not to collect any User data. This is a setting that is available in all major browsers. More information about opting out of Hotjar is available here.

Personal Data collected: Cookies; Usage Data; various types of Data as specified by the privacy policy of the service.

Place of processing: Malta - Privacy Policy - Opt Out.
Protection from SPAM

This type of services analyzes traffic on this Web Site, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.
Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
Use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.

Personal Data Collected: Cookies; Usage Data.

Place of processing: Ireland - Privacy Policy. Privacy Shield Adherent.
Advertisement

These types of services allow User Data to be used for marketing communication purposes in various forms of advertising, such as banners, also related to the User's interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are given below.
Some of the services below may use Cookies to identify the User or use the technique of behavioral retargeting, i.e. displaying advertisements tailored to the User's interests and behavior, also detected outside this Website. For more information on this, we suggest you check the privacy policies of the respective services.
In addition to the opt-out possibilities offered by the services below, the User may opt out with respect to receiving cookies related to a third-party service by visiting the Network Advertising Initiative opt-out page.
Facebook Audience Network (Facebook, Inc.)

Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook's use of data, please see Facebook's data policy.

To enable the operation of Facebook Audience Network, this Website may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for OS) or cookie-like technologies. Among the ways in which Audience Network delivers advertising messages to the User is by using the User's advertising preferences. The User can control the sharing of his or her advertising preferences within Facebook's Ad settings.

You may opt-out of certain Audience Network targeting features through your device settings. For example, you may change the settings on advertising available for mobile devices, or follow the instructions applicable to Audience Network that may be found within this privacy policy.

Personal Data Collected: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).

Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield Adherent.
Remarketing and behavioral targeting

These types of services allow this Web Site and its partners to communicate, optimize, and serve advertisements based on your past use of this Web Site.
This activity is carried out through tracking of Usage Data and the use of Cookies, information that is transferred to partners to which the remarketing and behavioral targeting activity is linked.
Some services offer an email list-based remarketing option.
In addition to the opt-out possibilities offered by the services below, the User may opt out with respect to receiving cookies related to a third-party service 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 links this Web Site's activity with the Facebook advertising network.

Personal data collected: cookies; email.

Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield Adherent.
Facebook Remarketing (Facebook, Inc.)

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

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield Adherent.
Remarketing Google Ads (Google LLC)

Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google LLC that links this Web Site's activity with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google's cookies for ad personalization by visiting Google's Ads Settings.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield Adherent.
Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.
Google Analytics (Google LLC)

Google Analytics is a web analytics service provided by Google LLC ("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 ads in its ad network.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield Adherent.
Google Ads Conversion Monitoring (Google LLC)

Google Ads conversion tracking is a statistics service provided by Google LLC that links data from the Google Ads ad network with actions taken within this Web Site.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy. Privacy Shield Adherent.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.).

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with actions taken within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook Ads, Instagram, and Audience Network ads.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy. Privacy Shield Adherent.
LinkedIn Conversion Monitoring (LinkedIn Corporation)

LinkedIn conversion tracking is a statistics service provided by LinkedIn Corporation that links data from the LinkedIn ad network with actions taken within this Web Site.

Personal Data Collected: Cookies; Usage Data.

Place of processing: United States - Privacy Policy. Privacy Shield Adherent.
Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Web Site and interact with them.
This type of service may still collect data on web traffic related to pages where the service is installed, even when users are not using it.
Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Web Site to integrate such content within its pages.

Personal Data Collected: Usage Data; various types of Data as specified by the service's privacy policy.

Place of processing: Ireland - Privacy Policy. Privacy Shield Adherent.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his/her Personal Data.
Object to the processing of their Data. You may object to the processing of your Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
access to your Data. You have the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
verify and request correction. Users may verify the accuracy of their Data and request that it be updated or corrected.
Obtain restriction of processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
Receive their Data or have their Data transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto.
propose complaint. The User may bring a complaint to the relevant data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are advised that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights

To exercise the User's rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Holder as soon as possible, in any case within one month.

Cookie Policy

This Web Site makes use of Cookies. To learn more and to view the detailed information, the User may consult the Cookie Policy.

More information about the treatment
Litigation defense

The User's Personal Data may be used by the Owner in legal proceedings or in the preparatory stages to its possible establishment for the defense against abuses in the use of this Web Site or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

Upon the User's request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Web Site 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 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 Web Site does not support "Do Not Track" requests.
To find out whether any third-party services used support them, the User is 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 as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will re-collect the User's consent, if necessary.

Definitions and legal references
Personal Data (or Data)

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

Usage Data

This is the information collected automatically through this Web Site (including by third party applications integrated into this Web Site), including: the IP addresses or domain names of the computers used by the User who connects with this Web Site, the addresses in URI (Uniform Resource Identifier) notation, 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..) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User's operating system and computer environment.

User

The individual using this Web Site who, except where 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 entity, public administration and any other entity that processes personal data on behalf of the Controller, as set forth in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the means adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.
This Web Site (or this Application)

The hardware or software tool by which Users' Personal Data are collected and processed.

Service

The Service provided by this Web Site as defined in the relevant terms (if any) on this site/application.
European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document is understood to extend to all current member states of the European Union and the European Economic Area.
Cookie

Small portion of data stored within the User's device.
Legal references

This privacy policy is prepared based on multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy covers this Web Site only.

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