This Website collects some Personal Data from its Users.
Owner and Data Controller
Project Spina Sagl - via S.Balestra 10 - 6900 Lugano (Svizzera)
Owner contact email: email@example.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: phone number, email address, first name, last name, Cookies, province, country, ZIP/Postal code, date of birth, city, address, fax number, Tax ID, User ID and Usage Data.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.
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 Website (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.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
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.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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: Access to third-party accounts, Contacting the User, Managing contacts and sending messages, Handling payments, Tag Management, Managing support and contact requests, Heat mapping and session recording and Hosting and backend infrastructure.
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.
Facebook permissions asked by this Website
This Website may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Access private data
Access the User's and friends' private data.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Access to third-party accounts
This type of service allows this Website to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (this Website)
This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Access private data.
Twitter account access (Twitter, Inc.)
This service allows this Website to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Contacting the User
Phone contact (this Website)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.
Personal Data collected: phone number.
Mailing list or newsletter (this Website)
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 Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data collected: address, city, Cookies, country, date of birth, email address, first name, last name, phone number, province and ZIP/Postal code.
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: address, city, country, date of birth, email address, fax number, first name, last name, Tax ID, User ID and ZIP/Postal code.
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
Braintree (PayPal Inc.)
Braintree is a payment service provided by Braintree, a division of PayPal, Inc.
Gestpay Banca Sella (Banca Sella S.p.A.)
Gestpay is a payment service provided by Banca Sella S.p.A.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Amazon Payments (Amazon)
Amazon Payments is a payment service provided by Amazon.com, Inc., which allows Users to make online payments using their Amazon credentials.
Android Pay (Google Inc.)
Android Pay is a payment service provided by Google Inc., which allows Users to make payments using their mobile phones.
Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Crazy Egg (Crazyegg)
Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data collected: Cookies and Usage Data.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.
Google Cloud Storage (Google Inc.)
Google Cloud Storage is a hosting service provided by Google Inc.
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.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
MailUp is an email address management and message sending service provided by MailUp SpA.
Personal Data collected: email address.
Managing support and contact requests
This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
All markets except Switzerland:
“In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.”
Switzerland only: Billpay’s/Klarna’s payment options: In order to be able to offer you Klarna’s payment options and to assess whether you qualify for their payment options and to tailor the payment options for you, we might in the checkout pass your personal data in the form of contact and order details to Klarna and Billpay. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s [de, fr, it or en versions] and Billpay’s [de, fr,it or en versions] privacy notices.”
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.
Additional information about Data collection and processing
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 Website 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
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (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 Website 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.
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.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).