PRIVACY POLICY OF WWW.MARKETINGTRADE.CO.UK
This Web Site collects certain Personal Data from its Users.
This document contains a section devoted to California consumers and their privacy rights.
This document contains a section devoted to Virginia consumers and their privacy rights.
This document contains a section devoted to Users residing in Brazil and their rights related to privacy.
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Data Controller
Marketing & Trade srl – corso di Porta Ticinese 60, 20123 Milano (ITALY)
Owner’s email address: info@marketingtrade.it
Types of Data Collected
Among the Personal Data collected by this Website, either independently or through third parties, are: Usage Data; Tracking Tools; number of Users; city; device information; session statistics; latitude (of the city); longitude (of the city); browser information; email; first name; last name; username; company name; various types of Data; Data disclosed while using the service.
Full details on each type of Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such Data.
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 is mandatory. If the User refuses to provide it, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users in doubt as to which Data are mandatory are encouraged to contact the Data Controller.
The possible 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 further 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 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
Methods of processing
The Data Controller 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) 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 of the processing
The Data Controller processes Personal Data related to the User in case one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: In some jurisdictions, the 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;
the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
the processing is necessary for the performance of a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.
However, it is always possible to ask the 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 Data Controller’s operational offices and at any other place 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 location of the processing, 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 consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the 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 Data Controller by contacting it at the contact details given at the beginning.
Retention Period.
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 Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes related 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 Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, 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 Data collected
User Data is collected to enable the Data Controller to provide the Service, comply with 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: Viewing content from external platforms, Statistics, Tag Management, Hosting and backend infrastructure, Contact management and messaging, Interaction with data collection platforms and other third parties, and Contacting the User.
To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details”.
Details of the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contacting the User
Mailing list or newsletter (this Website)
By registering for a mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information, including of a commercial and promotional nature, relating to this Web Site may be sent. The User’s email address may also be added to this list as a result of registering with this Web Site or after making a purchase.
Personal Data Processed: last name; Usage Data; email; first name; company name; Tracking Tools.
Category of personal information collected under the CCPA: identifiers; business information; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
Managing contacts and sending messages
These types of services allow the management of a database of email contacts, telephone contacts or contacts of any other type 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 viewing of messages, as well as the User’s interaction with them, such as information about clicks on links embedded in messages.
Mailchimp (Intuit Inc.)
Mailchimp is an address management and email message delivery service provided by Intuit Inc.
Personal Data Processed: last name; Data disclosed while using the service; Usage Data; email; name; company name; Tracking Tools; username; various types of Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; business information; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
a sharing pursuant to the CCPA
targeted advertising according to the VCDPA
Tag Management
This type of services is functional for the centralized management of tags or scripts used on this Website.
The use of such services involves the flow of User Data through them and, where appropriate, their retention.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
Hosting and backend infrastructure
The function of these types of services is to host Data and files that enable this Web Site to function, enable their distribution, and provide a ready-made infrastructure to deliver specific functionality of this Web Site.
Some services among those listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
SiteGround Hosting (SiteGround Hosting Ltd.)
SiteGround Hosting is a hosting service provided by SiteGround Hosting Ltd.
Personal Data Processed: Usage Data; Tracking Tools; various types of Data as specified by the service’s privacy policy.
Place of processing: United Kingdom – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; Internet information.
Interaction with data collection platforms and other third parties
These types of services allow Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
In case one of these services is installed, it is possible that, even if Users do not use the service, it will collect Usage Data related to the pages where it is installed.
Mailchimp Widget (Intuit Inc.).
The Mailchimp widget enables interaction with the Mailchimp email address management and message delivery service provided by Intuit Inc.
Personal Data Processed: last name; Usage Data; email; name; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
a sharing pursuant to the CCPA
targeted advertising according to the VCDPA
Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.
Histats (Wisecode)
Histats is a statistics service provided by Wisecode S.r.l.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: Italy – Privacy Policy – Opt out.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and the VCDPA.
Google Analytics 4
Google Analytics is a statistics service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, (“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 advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult Google’s official documentation.
Personal Data Processed: city; Usage Data; browser information; device information; latitude (of city); longitude (of city); number of Users; session statistics; Tracking Tools.
Place of Processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected under the CCPA: identifiers; Internet information; geolocation data.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
Displaying content from external platforms
This type of service allows users to view content hosted on external platforms directly from the pages of this Web Site and interact with them.
However, this type of service may collect web traffic data related to the pages where the service is installed, even when users are not using it.
Font Awesome (Fonticons, Inc. )
Font Awesome is a font style display service operated by Fonticons, Inc. that allows this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and VCDPA.
Google Fonts
Google Fonts is a font style display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing, that enables this Website to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and VCDPA.
Google Maps Widget
Google Maps is a map display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, which enables this Website to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
Instagram Widget
Instagram is an image display service operated by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of the Data, which allows this Website to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and VCDPA.
YouTube Video Widget
YouTube is a video content display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, which enables this Website to embed such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and VCDPA.
Vimeo Video (Vimeo, LLC).
Vimeo is a video content viewing service operated by Vimeo, LLC that allows this Web Site to embed such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
Adobe Edge Web Fonts (Adobe Systems Incorporated).
Adobe Edge Web Fonts is a font style display service operated by Adobe Systems Incorporated that allows this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; various types of Data as specified by the service’s privacy policy.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; Internet information.
This type of processing constitutes:
a sale under the CCPA and VCDPA.
Adobe Fonts (Adobe Systems Incorporated).
Adobe Fonts is a font style display service operated by Adobe Systems Incorporated that allows this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; various types of Data as specified by the service’s privacy policy.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: identifiers; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
MyFonts (Monotype Imaging Holdings Inc.).
MyFonts is a font style display service operated by Monotype Imaging Holdings Inc. that enables this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
A sale under the CCPA and the VCDPA.
Fonts.com Web Fonts (Monotype Imaging Holdings Inc.).
Fonts.com Web Fonts is a font style display service operated by Monotype Imaging Holdings Inc. that allows this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA.
Information on how to opt-out of interest-based advertisements
In addition to any opt-out features provided by any of the services listed in this document, Users may take advantage of information on YourOnlineChoices (EU), The Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services it is possible to manage the tracking preferences of most advertising tools. The Owner, therefore, advises Users to use these resources in addition to the information provided herein. AppChoices which helps Users control behavioral advertising on mobile applications.
Users can also disable certain advertising features through their respective device settings, such as device advertising settings for cell phones or ad settings in general.
User Rights
Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, to the extent permitted by law, Users have the right to:
revoke consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed.
object to the processing of their Data. The User may object to the processing of its 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 one’s own Data. The User has 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 rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
obtain restriction of processing. The User may request the limitation 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. The User may request the deletion of their Data by the Data Controller.
Receive their Data or have it transferred to another Data Controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller.
Propose Complaint. The User may lodge a complaint with the relevant data protection supervisory 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 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 should note that if their Data were processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reasons. If Users object to processing for direct marketing purposes, Personal Data are no longer processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to Exercise Rights
In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. The request may be filed free of charge and the Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, deletion or restriction of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller shall notify the User of such recipients if the User so requests.
Additional information on treatment
Defense in Court
The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of 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, i.e., files that record interactions and may also contain Personal Data, such as the User’s 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.
Responding 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, if 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 Controller will collect the User’s consent again, if necessary.
Da Information for Californian consumers al paragrafo “HOW AND WHEN WE ARE EXPECTED….” È già in inglese.
Information for Users residing in Brazil
This part of the document supplements and complements the information contained in the rest of the privacy policy and is provided by the entity that operates this Web Site and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we,” “our,” or “us”).
The provisions contained in this section apply to all Users who are residents of Brazil, within the meaning of the “Lei Geral de Proteção de Dados” (such Users are referred to hereafter simply as “you,” “your,” “you,” or “your”). For such Users, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy.
In this part of the document, the term “personal information” as defined by the Lei Geral de Proteção de Dados (LGPD) is used.
Legal basis under which we process your personal information
We process your personal information only where 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 organizations, preferably carried out on anonymized personal information;
the performance of a contract and related pre-contractual obligations, if you are a party to such a contract;
the exercise of our rights in court, administrative proceedings or arbitrations;
the defense or physical safety of you or a third party;
the protection of health – in the context of procedures put in place by health care entities or professionals;
our legitimate interest, provided that your fundamental rights and freedoms do not override such interests; and
credit protection.
To learn more about the legal basis, you may contact us at any time using the contact information provided in this document.
Categories of personal information processed
To find out what categories of personal information are processed, you can refer to the “Details of Personal Information Processing” section in this document.
Why we process your personal information
To know why we process your personal information, please refer to the sections “Details on the Processing of Personal Information” and “Purposes of the Processing of Data Collected” present in this document.
Your rights related to privacy in Brazil, how to submit a request, and how it will be handled by us
Your rights related to privacy in Brazil
You have the right to:
Obtain confirmation of the existence of processing activities regarding your personal information;
Access your personal information;
Obtain rectification of your incomplete, inaccurate or outdated personal information;
Obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or information that is processed contrary to the provisions of the LGPD;
obtain information regarding the possibility of giving or withholding your consent and its consequences;
Obtain information regarding the third parties with whom we share your personal information;
Obtain, upon your explicit request, portability of your personal information (except anonymized information) to other product or service providers, provided that our trade and industry secrets are safeguarded;
obtain the deletion of your personal information processed where the processing has been carried out on the basis of your consent, unless one or more of the exceptions in Article 16 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 body;
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; and
request review of decisions that harm your interests made solely on the basis of automated decision-making processes of your personal information. These include decisions to delineate your personal, professional, consumer or creditor profile, or other facets of your personality.
You will never be discriminated against, or suffer in any way any treatment that is unfavorable to you, as a result of exercising your rights.
How to submit a request
You can submit an explicit request to exercise your rights free of charge, at any time, using the contact information in this document or through your legal representative.
How and how quickly we will handle your request
We will make every effort to respond to your request as quickly as possible.
In any case, if it is impossible for us to do so, we will be sure to inform you of the factual or legal reasons why we are unable to immediately fulfill or follow up on your request. In the event that your personal information is not processed by us, if we are able to do so, we will direct you to the natural or legal person to whom your requests should be addressed.
Should you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please be sure to specify whether you prefer to receive your personal information in electronic or paper format.
You should also let us know if you would like an immediate response, in which case you will receive a simplified response, or if you require a full disclosure.
In the latter case, we will respond within 15 days from the time of your request, providing you with all the information regarding the origin of your personal information, whether or not we confirm the existence of personal information about you, all the criteria used for processing, and the purposes of such processing, while safeguarding our trade and industry secrets.
In the event that you decide to submit a request for rectification, erasure, anonymization or blocking of personal information, we will ensure that we immediately inform other parties with whom we have shared your personal information of your request so that they can in turn comply with your request – except in cases where such a communication is impossible or unduly burdensome for us.
Transfer of personal information outside 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 between intelligence services, investigative and criminal procedure bodies, as provided 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 the ANPD;
when the transfer results from an obligation undertaken in the context of an international cooperation agreement;
when the transfer is necessary for the exercise of public policy or the performance of a public service;
when the transfer is necessary for the fulfillment of a legal obligation, the performance of a contract and related pre-contractual fulfillments, or the normal exercise of rights in guidiatorial, administrative, or arbitration proceedings.
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.
Data Subject
The natural person to whom the Personal Data refers.
Data Controller (or 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 Controller).
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 instruments 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.