1. WHAT AND WHO IS COVERED BY THIS PRIVACY POLICY?

The Company is the controller of personal data (e.g. information that identifies a specific person, such as full name or email address) that we collect from and about you through the Company Services that are processed in accordance with the terms of this Privacy Policy.

This Privacy Policy, as well as our Cookie Policy, apply to all users, including those who use the Company Services without having registered or subscribed to any Company Service and those who have registered or subscribed to any Company Service. As set out in our Terms of Use, the Company Services are intended for the general public, are not directed to children and do not knowingly collect personal data from children under 16 years of age.

2. WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

The Company collects (1) registration data, when you register or sign up for a Company Service, (2) public data and posts shared through the Company Services, (3) data that you have allowed social media to share with the Company, (4) activity data when you access and interact with a Company Service. Specifically, the Company collects the following types of data from and about you:

Registration Data, which is the information you submit to register for a Company Service, for example to create an account, post comments, receive a newsletter or enter a contest. Registration Information may include, for example, your first name, last name, email address, gender, country, postal code and date of birth.
Public Data and Posts which consists of comments or content you post on the Company Services and your personal data accompanying such posts or content, which may include your nickname, username, comments, likes, status, profile information and photo. Public information and posts are always public, which means they are available to anyone and may appear in search results on external search engines.
Social Media Data. If you access or log in to a Company Service through a social media service or connect a Company Service to a social media service, the data we collect may also include your user ID and/or username associated with that social media service, information or content you have authorized the social media service to share with us, as well as your profile picture, email address or friends lists, and any personal data you have made public in connection with that social media service. When you access the Company Services through social media services or when you connect a Company Service to social media services, you authorize the Company to collect, store and use the relevant personal data and content in accordance with this Privacy Policy.
Activity Data. When you access and interact with the Company Services, we may collect certain information about those visits. For example, to enable your connection to the Company Services, our servers receive and record information about your computer, device, and browser, including your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device. We may also collect cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology commonly referred to as “Flash cookies”). These technologies may be used to collect and store information about your use of the Company Services, such as the pages you have visited, the video and other content you have viewed, the search queries you have submitted, and the advertisements you have seen. For more information, please see our Cookie Policy.
Information from other sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.

We do not collect:

Financial information from a payment service provider: In some cases, we may use an unaffiliated payment service to enable you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment through a Payment Service, you will be directed to a Payment Service website. Any information you provide to a Payment Service will be subject to the Payment Service’s privacy policy and not to this Privacy Policy. We have no control over, and are not responsible for, any use by the Payment Service of information collected through any Payment Service.
Sensitive Information: We ask that you do not send us or disclose sensitive personal information (such as social security numbers, information about racial or ethnic origin, political opinions, religion or other beliefs, health, criminal history, or trade union membership) on or through the Company Services or otherwise.

Linked Services
Finally, the Company Services may also link to websites, including social networking sites, that are operated by non-affiliated companies, and may provide advertisements or offer content, functionality, games, newsletters, contests, or applications developed and maintained by non-affiliated companies. The Company is not responsible for the privacy practices of non-affiliated companies, and you should review the applicable Privacy Policy of the other service once you leave the Company Services or click on an advertisement.

Functionality cookies
These cookies “remember” your preferences while browsing our site, so that we can recommend the right products based on your needs. With these cookies you enjoy a personalized experience, making it much easier to find what you are looking for.

3. HOW DO WE USE YOUR PERSONAL DATA?

We use the personal data we collect from and about you to:

• Provide you with the Company Services and Features,
• Measure, analyze and improve such Company Services and Features,
• Enhance your experience through the Company Services (both online and offline) by providing content that you may find relevant and interesting,
• Allow you to comment on content and participate in online games, contests or reward programs,
• Provide you with customer service and respond to your questions,
• Protect the rights of the Company and others. For example, there may be instances in which the Company may use your personal data, including where the Company believes, in good faith, that such processing is necessary to: (i) protect, enforce or defend the legal rights, safety or property of the Company, the Company’s affiliates or their employees, agents, contractors, licensors and suppliers (including enforcing our agreements and terms of use), (ii) protect the safety, privacy and security of users of the Company’s Services or the public, (iii) protect the Company, as well as other involved third parties, such as the Company’s suppliers, from fraud or for risk management purposes,
• For the purposes of complying with applicable laws or legal process and/or to respond to requests from competent government authorities.
• To complete a a corporate transaction such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of the business, assets or stock of the business (including any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or substantially all of its business, the Company may disclose and transfer your personal data to the party or parties involved in the transaction as part of such transaction,
• To allow social interaction functionality – if you log in or connect a social media service account to the Company Services, we may share your username, photo and likes, as well as your activities and comments with other users of the Company Services and with your friends associated with your social media service. We may also share the same personal data with the social networking service provider,
• Send you (via email, SMS, telephone, chat and social media), with your prior consent, offers, promotions and other commercial communications regarding the Company’s Services.
• Send you, with your prior consent, commercial communications tailored to your interests and needs through the communication methods referred to in point j) above.

We may use anonymous data or data that no longer identifies you personally, even indirectly (e.g. statistics) for any purpose or share it with third parties.

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

The processing of your personal data for the purposes of:
Section 3, points a) to f) of this Privacy Policy is necessary to provide the requested services and, therefore, is mandatory, because otherwise the services could not be provided,Section 3, point g) of this Privacy Policy is requested in accordance with applicable laws and, therefore, is also mandatory.

Section 3, point h) of this Privacy Policy is carried out on the basis of the legitimate interest of the Company and its counterparties to carry out such economic activities. This interest is sufficiently balanced with your own interest, given that the data processing is carried out within the strictly necessary limits of exercising such economic activities. This data processing activity is not mandatory and you can object at any time as described in Section 11 of this Privacy Policy.

On the contrary, the processing of your personal data for the remaining purposes:
Section 3, point (i) is at your discretion, but without your consent it is impossible to link a social media service account to the Company Service, which means that you will have to log in to the Company Service using a different mechanism,

Section 3, points (j) and (k) are at your discretion, but without your consent it is impossible for the Company and/or third parties to provide you with general commercial communications of the Company and services/products or third party communications based on your interests and needs and to provide you with services under the same brand. You may withdraw your consent to the processing of your personal data for the purposes of Section 3, points i) to k), at any time by sending a notification to the email address described in Section 11 below.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

Your personal data are processed by both electronic and manual means and are protected by appropriate security measures, taking into account the state of the art, the cost of implementation and the nature, scope, context and purpose of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of individuals. In particular, the Company uses appropriate administrative, technical, personnel and physical measures aimed at protecting the personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

6. WHO MAY OBTAIN ACCESS TO YOUR PERSONAL DATA?

The Company may disclose your personal data for the purposes of Section 3 above to the following categories of recipients located within the European Union or outside the European Union in accordance with and within the limits of the provisions of Section 7 below:

To third party service providers who are entrusted with processing activities and, where required by applicable laws, are duly appointed as processors (e.g. cloud service providers, other group organizations, service providers that service or support the Company’s Service and therefore, for example and without limitation, companies providing IT services, experts, consultants and lawyers-companies resulting from possible mergers, divisions or other transformations, and
To affiliated companies in their capacity as controllers data processors or data processors.
To the competent authorities for the purposes of compliance with applicable laws.
The data processors appointed by the company include the provision of IT services. You can request a full list of the data processors appointed from the Company at the address indicated in Section 11 of this Privacy Policy.

7. ARE YOUR PERSONAL DATA TRANSFERRED ABROAD?

Data may be transferred to countries within and outside the European Economic Area and in particular to the Americas. The European Commission recognises that certain countries outside the EEA provide an adequate level of data protection in accordance with EEA standards. The full list of these countries is available at

http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.

For transfers from the EEA to countries not considered safe by the European Commission, we have put in place suitable and appropriate safeguards aimed at protecting your personal data and transferring your personal data in accordance with applicable data protection laws, such as standard contractual clauses adopted by the European Commission in accordance with Articles 45 and 46 of Regulation (EU) 2016/679 on data protection (the “GDPR”). You have the right to request a copy of the above measures and further information regarding your personal data by contacting the Company at the address indicated in Section 11 of this Privacy Policy.

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

You have the right, at any time, to:

receive confirmation as to whether your personal data exist and be informed of their content and origin, verify their accuracy and request their correction, updating or modification,
request the deletion, anonymization or restriction of the processing of your personal data processed in violation of applicable law,
object to the processing, in all cases, of your personal data for legitimate reasons.

You can send your request to the address indicated in Section 11 below. In your request, please include your email address, name, address and telephone number and clearly specify the information you wish to access, change, update, remove or delete. We remind you that. Even after you cancel your account, or if you ask us to delete your personal data, copies of some information from your account may remain visible in certain circumstances, such as if you have shared information on social media or other services, or, for example, when retaining such copies is necessary to comply with legal obligations or for legal defense purposes. Due to the nature of caching technology, your account may not be immediately inaccessible to others. We may also retain backup information about your account on our servers for a period of time after cancellation or your request for deletion, for the purposes of complying with applicable law.

We also give you many choices regarding the use and disclosure of your personal data for marketing purposes. You can withdraw your consent to:

Receive electronic communications from us. If you no longer wish to receive marketing-related emails from us, you may opt out of receiving marketing-related emails either by following the unsubscribe instructions in our communications or by simply changing your preferences in your user profile settings if you are a registered user or through the consent management tool available on our website if you are not a registered user. You may also send a request to the address listed in Section 11 of the Privacy Policy. In any event, the Company may continue to send you administrative communications related to the provision of the Company’s Services.
Share your personal information with affiliates of the Company or with business partners for their own marketing purposes. If you prefer not to have your personal information shared on an ongoing basis with company affiliates and/or business partners for their direct marketing purposes, you may opt out of such sharing either by simply changing your preferences in your user profile settings, if you are a registered user, or through the consent management tool available on our website, if you are not a registered user, or by sending a request to the address in Section 11 of the Privacy Policy.

In all of the above cases, we may contact you and ask you for more information, which is necessary for the proper processing of your request. Also, the additional rights described in Section 9 below apply from May 25, 2018.

9. WHAT APPLIES FROM MAY 25, 2018?

As of May 25, 2018, the General Data Protection Regulation has entered into force and the following provisions apply:

Retention periods applicable to your personal data

We will retain your data only for the period necessary to fulfill the purposes for which the data were collected as described in this Privacy Policy. In any case, the following retention periods will apply with regard to the processing of your personal data for the purposes set out below:

The data collected for the purposes set out in Section 3, points a) to h) of this Privacy Policy are retained for the duration of the provision of the Company’s Service, plus the duration of the limitation period in accordance with applicable law, after the termination of the Company’s Service. The data collected for the purposes of Section 3, point i) of this Privacy Policy are retained for the period of time necessary to log in to the Company Service via a social network, and
The data collected for the purposes of Section 3, point j) are retained in a form which permits identification of data subjects only for the period necessary for the purposes of processing the personal data; the personal data may be stored for longer periods, provided that the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in accordance with Article 89(1) of the General Data Protection Regulation and provided that the appropriate technical and organizational measures required by this Regulation to safeguard the rights and freedoms of the data subject (“storage period limitation”)
The data collected for the purposes of Section 3, point k) are retained in a form which permits identification of data subjects only for the period necessary for the purposes of processing the personal data; the personal data may be stored for longer periods, provided that the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, in accordance with Article 89(1) of the General Data Protection Regulation and provided that the appropriate technical and organizational measures required by this Regulation to safeguard the rights and freedoms of the data subject are implemented (“storage period limitation”)
The data collected for the purposes of Section 3, point k) are retained in a form which permits identification of data subjects only for the period necessary for the purposes of the processing of the personal data; personal data may be stored for longer periods provided that the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the General Data Protection Regulation and provided that the appropriate technical and organisational measures required by this Regulation to safeguard the rights and freedoms of the data subject are implemented (‘storage limitation’). At the end of the retention period, your personal data will be erased, anonymised or aggregated.

Additional rights

In addition to the rights referred to in Section 8 of this Privacy Policy and pursuant to the application of the General Data Protection Regulation, you will also have the right, at any time, to:

Request the Company to restrict the processing of your Personal Data in the event that:

You contest the accuracy of the personal data until we have taken the necessary steps to correct or verify their accuracy,

The processing is unlawful, but you do not want us to erase your personal data,

We no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims, or

You have objected to the processing on grounds of legitimate interests pending verification as to whether the Company has compelling legitimate grounds to continue the processing.
Object to the processing of your personal data,
Request the erasure of your personal data without undue delay,
Receive an electronic copy of your personal data if you wish to transfer your personal data that you have provided to us, either to yourself or to another provider (“data portability”)< when the personal data is processed by automated means and the processing is either (i) based on your consent or (ii) is necessary for the performance of the Company Service, and
Submit a complaint to the competent data protection supervisory authority.

10. UPDATES TO THIS PRIVACY POLICY

The Company may modify or update this Privacy Policy for any reason (including, without limitation, changes in applicable law and interpretations, decisions, opinions and orders regarding such applicable law.) Please refer to the Effective Date at the top of this Privacy Policy to see when it was last revised. Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on the Company Services. In the event that we make material changes to this Privacy Policy that change the nature of the processing or expand our rights regarding the use of personal data that we have already collected from you, we will notify you and provide you with a choice regarding the future use of such personal data, as may be required by applicable law.