Effective starting: May 24, 2018
This policy explains the what, how, and why of the information we collect when you visit one of our Websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell any information.
We take your and your End Users privacy extremely seriously
We never sell any information
Customer data – any information about customers of ETI Services – are shared with some third parties that help us to provide better customer experience within ETI service
End Users data – any information about customers’ End Users when using People tracking and Analytics features, once ETI is implemented on customer’s application
are not shared with ANY third-party
never leaves ETI’s hosting infrastructure
Communications between our service, customers portals and ETI products are all encrypted via SSL
Information We Collect
Among the types of Personal Data that ETI collects, by itself or through third parties, there are:
Various types of Data
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using ETI.
Unless specified otherwise, all Data requested by ETI is mandatory and failure to provide this Data may make it impossible for ETI to provide its services. In cases where ETI 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 ETI 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 ETI (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 data protection laws of your local jurisdiction;
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 their country of origin 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: Analytics, Contacting the User, Content commenting, Handling payments, Displaying content from external platforms, Infrastructure monitoring, Interaction with support and feedback platforms, Managing contacts and sending messages, Managing support and contact requests, Social features, Remarketing and behavioral targeting, Tag Management and Data transfer outside the country of origin.
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.
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.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Google Analytics (Google Inc.)
Facebook Ads conversion tracking (Facebook, Inc.)
Google AdWords conversion tracking (Google Inc.)
Twitter Ads conversion tracking (Twitter, Inc.)
AWS (Amazon Web Services)
CloudNoc (CloudNoc, Inc)
Clearscale (Clearscale, Inc.)
Managing contacts and sending messages
HubSpot (HubSpot, Inc.)
SalesForce (Salesforce, Inc.)
Managing support and contact requests
Remarketing and behavioral targeting
Facebook Custom Audience (Facebook, Inc.)
Facebook Remarketing (Facebook, Inc.)
AdWords Remarketing (Google Inc.)
Twitter Remarketing (Twitter, Inc.)
Twitter Tailored Audiences (Twitter, Inc.)
Google Tag Manager (Google LLC)
Inviting and suggesting friends (ETI)
Public profile (ETI)
Further information about Personal Data
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through ETI to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Selling services online
The Personal Data collected are used to provide the User with services, including payment and possible delivery.
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. ETI may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. ETI adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
to enable or otherwise improve the decision-making process;
to grant Users fair and unbiased treatment based on consistent and uniform criteria;
to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within ETI, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
PayPal might also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal (PayPal Inc) – PayFlow Pro is a payment service provided by PayPal Inc.
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 ETI 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, ETI and any third-party services may collect files that record interaction with ETI (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 end of this document.
How “Do Not Track” requests are handled
ETI 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.
No Children Under Age 13
Users declare themselves to be adult according to their applicable legislation. Minors may use ETI only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use ETI.
The Security Measures applicable to the Services are described here (as updated from time to time).
Data transfer outside the country of origin
The Owner is allowed to transfer Personal Data collected within the country of origin to third countries (i.e. any country other than the one where data was originally provided) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Data transfer abroad based on consent (ETI)
If this is the legal basis, Personal Data of Users shall be transferred from the country of origin to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via ETI.
Data transfer abroad based on standard contractual clauses (ETI)
If this is the legal basis, the transfer of Personal Data from the country of origin to third countries is carried out by the Owner according to “standard contractual clauses” provided by the data protection laws in the country of origin.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by data protection legislation in the country of origin. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Other legal basis for Data transfer abroad (ETI)
If no other legal basis applies, Personal Data shall be transferred from the country of origin to third countries only if at least one of the following conditions is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via ETI.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
“Personal Data (or Data)” means 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.
“Usage Data means” information collected automatically through ETI (or third-party services employed in ETI), which can include: the IP addresses or domain names of the computers utilized by the Users who use ETI, 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.
“User” means the individual using ETI who, unless otherwise specified, coincides with the Data Subject.
“Data Subject” means the natural person to whom the Personal Data refers.
“Data Controller (or Owner)” means 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 ETI. The Data Controller, unless otherwise specified, is the Owner of ETI.
“ETI (or this Application)” means the means by which the Personal Data of the User is collected and processed.
“Service” means a service provided by ETI as described in the relative terms (if available) and on this site/application.
“Cookies” means a small piece of data stored in the User’s device.