Owner and Data Controller

Initala –

Email address of the Data Controller: privacy@initala.com

 

Types of data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: Cookies; Usage data; first name; last name; telephone number; email address; various types of Data.

Full details of each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of the data.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory, are encouraged to contact the Owner.
Any use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

 

Mode and place of processing of the collected Data

Methods of processing

The Data Controller shall take appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using computer and/ or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external parties may have access to the Data (as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller. The updated list of Data Processors may always be requested from the Data Controller.

Legal terms

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

  • the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the consent of the User or another of the legal bases specified below, until the User opposes ("opt-out") such processing. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
  • the processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
  • processing is necessary for the performance of a task in the public interest or for the exercise of official authority vested in the Owner;
  • processing is necessary for execution

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Location

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

The User has the right to obtain information about the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details of the processing of Personal Data or ask for information from the Data Controller by contacting him at the opening details.

Retention period

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

Therefore:

  • The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
  • The Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. In addition, the Data 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, upon expiry of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

 

Purposes of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Statistics, Contacting the User, Interaction with external social networks and platforms and Displaying content from external platforms.

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

 

Details on the processing of Personal Data

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

Contact the user

Contact form (Website)

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

Personal Data processed: name; surname; email; telephone number; various types of Data.

Interaction with external social networks and platforms

This type of service allows you to interact with social networks, or with other external platforms, directly from the pages of this Website. The interactions and information acquired by this Website are in any case subject to the User’s privacy settings related to each social network. This type of service may still collect traffic data for pages where the service is installed, even when Users do not use it. We recommend that you log out of the respective services to ensure that the data processed on this Website is not linked to your profile.

Facebook button and social widgets (Facebook, Inc.)

The "Like" button and Facebook social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.

Personal Data processed: Cookies; Usage data.

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

Youtube social button and widgets (Google Inc.)

The Youtube button and social widgets are services of interaction with the social network Youtube, provided by Google Inc.

Personal Data processed: Cookies; Usage data.

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

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of the User’s behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. ("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 the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Cookies; Usage data.

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

Facebook Ads Conversion Tracking (Facebook pixels) (Facebook, Inc.)

The Conversion Tracking of Facebook Ads (Facebook pixels) is a statistical service provided by Facebook, Inc. that connects data from the Facebook ad network with the actions carried out within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram, and Audience Network ads.

Personal Data processed: Cookies; Usage data.

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

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
In the case in which a service of this type is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.

Widget Instagram (Instagram, Inc.)

Instagram is an image visualization service provided by Instagram, Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage data.

Place of processing: United States - Privacy Policy.

Widget Video YouTube (Google Inc.)

Youtube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage data.

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

Widget Google Maps (Google Inc.)

Google Maps is a map visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage data.

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

 

Rights of the user

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

In particular, the User has the right to:

  • withdraw consent at any time.The User may revoke consent to the processing of their Personal Data previously expressed.
  • object to the processing of their Data.The User may object to the processing of their Data when it takes place on a legal basis other than consent. Further details on the right to object are given in the section below.
  • access their Data.The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification.The User can verify the correctness of their Data and request its update or correction.
  • obtain the limitation of treatment.When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
  • obtain the deletion or removal of their Personal Data.When certain conditions are met, the User may request the deletion of their Data by the Owner.
  • receive your Data or have it transferred to another data controller.The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures related to it.
  • lodge a complaint.The User may lodge a complaint with the competent personal data protection supervisory authority or act in court.

Details on the right of objection

When the Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

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

 

This Website uses Cookies and other Identifiers. To learn more, the User can consult the Cookie Policy.

 

More information on the processing

Legal defence

The User’s Personal Data may be used by the Data Controller in court or in the stages preparatory to its possible establishment for defence against abuse in the use of this Website or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information

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

System logs and maintenance

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

Information not contained in this policy

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

Response to "Do Not Track" requests

This Website does not support "Do Not Track" requests.
To find out if any third-party services used support them, the User is invited 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 and, where technically and legally feasible, sending a notification to Users through one of the contact details of which it is in possession. Please, therefore, 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 Owner will collect the User’s consent again, if necessary.

 

Definitions and legal references

Personal Data ( or Data)

Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Data of use

This is information collected automatically through this Website (including by third-party applications integrated into this Website), including: IP addresses or domain names of computers used by the User that connects with this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in reply, 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 the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details of the itinerary followed inside the Application, with particular reference to the sequence of pages consulted, the parameters related to the operating system and the computer environment of the User.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Processor)

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

Data Controller (or Data Controller)

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

This Website (or this Application)

The hardware or software tool through which Personal Data of Users are collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie

Small amount of data stored inside the User’s device.

Legal references

This Privacy Statement is prepared on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679. Privacy Statement. Unless otherwise specified, this privacy policy relates exclusively to this Website.