Privacy Policy

Data Controller

Luigi Marino / Creact SAS – Viale Traiano, 339 – 80126 Napoli

Email address of the Data Controller: [email protected]

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: Cookies; Usage data; first name; last name; e-mail address; telephone number; company; unique identifiers of advertising devices (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 information texts displayed before the data are 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 are 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 on its operation.
Users who are not sure about which Data are mandatory are encouraged to contact the Data Controller.
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 all the other 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 he guarantees that he has the right to communicate or disclose them, therefore freeing the Data Controller from any liability to third parties.

How and where Personal Data are processed
Processing methods

The Data Controller adopts the appropriate security measures in order to prevent 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 that are strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects may have access to the Data, including personnel involved in the organization of this Website (administrative, commercial, marketing, legal personnel, as well as system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) that can also be appointed, if necessary, Data Processors by the Owner. The updated list of Data Processors can always be requested to the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some legal systems, the Data Controller may be authorized to process Personal Data without the User’s consent or without another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is 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 performance of pre-contractual measures;
processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
processing is necessary for the performance of a public interest task or for the exercise of public powers with which the Data Controller is invested;
processing is necessary for the pursuit of the legitimate interest of the Owner 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 in a contract or necessary to conclude a contract.

Place

The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section relating to the details concerning the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of 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 can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or requesting information from the Data Controller by contacting him at the contact details indicated at the beginning of this policy.

Retention period

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

Therefore:

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

When the processing is based on the User’s consent, the Data Controller can keep the Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of the processing of the collected Data

User Data are collected in order to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect his rights and interests (or those of Users or third parties) and identify any malicious or fraudulent activities, as well as for the following purposes: Statistics, Contacting the User, Remarketing and Behavioural Targeting, Advertising, Heat mapping and session recording, Spam Protection and Display of content from external platforms.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.

Details on the processing of Personal Data

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

Contact the User
Contact form (this Website)

By filling in the contact form with their Data, the User consents to their use to answer to requests for information, quotes, or any other purpose indicated by the form header.

Personal Data collected: last name; e-mail address; first name; phone number; company.

Heat mapping and session recording

Heat mapping services are used to identify which areas of a page are subject to cursor movement or mouse clicks in order to detect which of them attract the most interest. These services allow to monitor and analyze traffic data and are used to keep track of User behaviour.
Some of these services may record sessions and make them available for later viewing.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects the generic “Do Not Track” headers. This means that the browser can tell the script not to collect any User data. It is a setting that is available in all major browsers. More information on the opt-out from Hotjar is available here.

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

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

Spam protection

This type of service analyzes the traffic of this Website, which potentially contains Users’ Personal Data, 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.
The 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. Subject adhering to the Privacy Shield.

Advertising

This type of service allows to use the User’s Data for commercial communication purposes in various advertising forms, such as the banner, also in relation to the User’s interests.
This does not mean that all Personal Data are used for this purpose. Data and conditions of use are indicated below.
Some of the services indicated below may use Cookies to identify the User or use the behavioural retargeting technique, that is, displaying personalized advertisements based on the interests and behaviour of the User, detected also outside of this Website. If you want to learn more in this respect, we suggest you check the privacy policies of the respective services.
In addition to the options to opt-out that are offered by the services listed below, the User can opt for the exclusion from the reception of cookies relating 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. To learn more about Facebook’s use of data, please consult Facebook’s data regulations.

To allow the Facebook Audience Network to work, this Website may use some identifiers for mobile devices (including Android Advertising ID or iOS Advertising Identifier) or technologies similar to cookies. Among the ways in which Audience Network offers advertising messages to the User, there is also the use of the latter’s advertising preferences. The User can control the sharing of his advertising preferences within the Facebook Ad settings.

The User can opt-out from some Audience Network targeting functions through the settings of their device. For example, you can change the advertising settings available for mobile devices, or follow the instructions applicable to the Audience Network that may be present within this privacy policy.

Personal Data collected: Cookies; Usage data; unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example).

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Remarketing and Behavioural Targeting

This type of service allows this Website and its partners to communicate, optimize and offer advertisements based on the past use of this Website by the User.
This activity is carried out through the tracking of Usage Data and the use of Cookies, collecting information that is transferred to the partners to whom the remarketing and behavioural targeting activity is linked.
Some services offer a remarketing option based on e-mail addresses lists.
In addition to the options to opt-out offered by the services listed below, the User can opt for the exclusion from the reception of cookies relating 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 behavioural targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies; e-mail.

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Facebook Remarketing (Facebook, Inc.)

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

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Remarketing Google Ads (Google LLC)

Remarketing Google Ads is a remarketing and behavioural targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

Users can choose not to use Google cookies for ad personalization by visiting the Google Ad Settings.

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Statistics

The services listed in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour.

Google Analytics (Google LLC)

Google Analytics is a web analysis 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 could use Personal Data to contextualize and personalize the advertisements of its advertising network.

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Google Ads conversion tracking (Google LLC)

Google Ads conversion tracking is a statistics service provided by Google LLC that connects data from the Google Ads ad network with the actions performed on this Website.

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.

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 ad network with the actions performed on this Website. The Facebook pixel monitors the conversions that can be attributed to Facebook, Instagram and Audience Network advertisements.

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.

LinkedIn conversion tracking (LinkedIn Corporation)

LinkedIn conversion tracking is a statistics service provided by LinkedIn Corporation that connects data from the LinkedIn ad network with the actions performed on this Website.

Personal Data collected: Cookies; Usage data.

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.

Content visualization from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website, as well as to interact with such content.
This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style visualization service managed by Google Ireland Limited that allows this Website to integrate such content within its pages.

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

Place of processing: Ireland – Privacy Policy. Subject adhering to the Privacy Shield.

User rights

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

In particular, the User has the right to:

withdraw consent at any time. The User can withdraw his previously expressed consent to the processing of his Personal Data.
oppose the processing of his Data. The User can object to the processing of his Data when it takes place on a legal basis other than consent. Further details on the right to object are indicated in the section below.
access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the processed Data.
verify and request correction. The User can verify the correctness of his Data and request its updating or correction.
obtain a limitation of the processing. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose other than their conservation.
obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
receive his Data or have them transferred to another holder. The User has the right to receive their Data in a format that is structured, commonly used and readable by an automatic device. The User has also the right, where technically feasible, to obtain the transfer of Data without obstacles to another holder. This provision is applicable when the Data are 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.
lodge a complaint. The User can lodge a complaint with the competent personal data protection control authority or take legal action.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public powers with which the Data Controller is invested or to pursue a legitimate interest of the Owner, Users have the right to oppose the processing for reasons related to their particular situation.

Users are reminded that, if their Data were processed for direct marketing purposes, they can oppose the processing without giving any reasons. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

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

Cookie Policy

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

Further information about the processing

Defense in court

The User’s Personal Data may be used by the Owner in court, or in the preparatory stages for 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 Data Controller may be obliged to disclose the Data by order of the public authorities.

Specific information

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

System log files and maintenance

For needs related to operation and maintenance, this Website and any third-party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not included in this policy

Further information in relation to the processing of Personal Data may be requested at any time to the Owner using the contact details.

Response to “Do Not Track” requests

This Website does not support “Do Not Track” requests.
To find out if any of the third-party services used support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying it to Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details he has. Please therefore consult this page frequently, referring to the date of the last modification that is indicated at the bottom.

If the changes concern processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

By Personal Data we mean 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.

Usage Data

These are the information collected automatically through this Website (and also from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the addresses in URI (Uniform Resource Identifier) ​​notation, the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numeric 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 related to the itinerary followed within the Website, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses this Website which, unless otherwise specified, coincides with the Interested Party.

Interested Party

The natural person to whom the Personal Data refers.

Data Processor

The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of Personal Data and the tools adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

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

Service

The Service provided by this Website as defined in the respective terms (if any) on this Website/Application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union included in this document is intended to be extended 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 has been 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 only concerns this Website.

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