PRIVACY POLICY OF THE WWW.LIFEEL.EU

For us your privacy and the security of your personal data are very important, for this reason we collect and manage your personal data with the utmost attention and take specific measures to keep it safe. Below you will find the main information about our processing of your personal data in relation to your navigation on the site and the use of the services offered. For detailed guidance on how we manage your personal data we invite you to read all our Privacy Policy.

Data Controller

Cesare Mario Puzzi, Communication Manager of the LIFEEL Project (from now on Owner or Data Controller) and CEO of the Company G.R.A.I.A. S.r.l.

Registered office G.R.A.I.A. S.r.l.: Via Repubblica, 1 21020 Varano Borghi (VA) Italy

Owner’s email address: cesare.puzzi@graia.eu

Types of data collected

Among the Personal Data collected by this Website, independently or through third parties, there are but not limited to: email, first name, surname, website, Cookies, Usage Data and other types of Data.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the collection of the data.

Personal Data may be freely provided by you or, in the case of Usage Data, automatically collected during the use of this website.

Unless otherwise specified, all data required by this Website is required to perform the services (Contact Request and/or Newsletter Subscription). If you refuse to disclose them, it may be impossible for the Data Controller to provide the service. In cases where this Website indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any effect on the availability of the Service or its operation.

Users who have doubts about which data is mandatory, are encouraged to contact the data controller.

The possible use of Cookies – or other tracking tools – by this Website or by the owners of the third-party services used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the specific chapter of the Cookie Policies.

Communication of data to third parties for marketing purposes

Please note that, for no reason will the Data provided by you, collected by this site or c/o the user himself, be transmitted to third parties for different purposes (e.g. Marketing or commercial communications) from those specified in this policy.

You assume responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantee that you have the right to communicate or disseminate them, freeing the Data Controller from any liability to third parties.

How and where the collected data are treated

How to treat

The Data Controller shall take appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing can be carried out both through IT and /or telematic and analog tools, with organizational methods and with logics closely related to the indicated purposes.

In addition to the Data Controller, in some cases, other subjects involved in the Owner’s organization (administrative, commercial, 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 Controllers by the Data Controller, may have access to the Data.

Some of these Managers are expressly indicated in this information in the specific section and in any case the complete and updated list of Managers can always be requested from the Data Controller.

Legal bases for processing

The Data Controller treats Personal Data relating to the User in case there is at least one of the following conditions:

  • you have given your consent for one or more specific purposes;
  • processing is necessary for the performance of a contract with you and/or for the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the execution of a task of public interest for the exercise of public powers of which the Data Controller is invested;
  • processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties (e.g. deriving from customer/supplier/Partner relationship)

If it is not sufficiently specified in this information, it is always possible to request 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.

Place

The processing connected to the web services of this Portal takes place at the data controller’s offices or at those of third parties who carry out processing operations on behalf of the Data Controller and have been duly reviewed as Data Controllers pursuant to art. 28 of the GDPR.

The Data Controller shall take appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the personal data being processed.

The processing is carried out through IT and /or telematic tools, with organizational methods and with logics closely related to the indicated purposes.

The treatment operations are carried out only by technical personnel in charge of the treatment, or maintenance operations. These subjects, duly identified and authorized, have received specific instructions on the methods and purposes of the processing.

Retention period

The 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 pre-contract or contract (e.g. request for information, contact) between the Data Controller and the User will be withheld until the execution of such contract is completed;
  • personal Data collected for purposes attributable to the legitimate interest of the Data Controller (e.g. protection from SPAM) will be withheld until this interest is fulfilled;
  • when the processing is based on your consent (e.g. subscription to optional newsletters and cookies), the Data Controller will retain personal data until such consent is revoked through the unbling services, or another right of the data subject is exercised (e.g. right of deletion of data or right of objection);
  • the Data Controller retains the personal data collected by the User for as long as such information is considered relevant for commercial purposes on the basis of legitimate interest and, in any case, up to a maximum of 36 months from the last useful contact (intended as a useful contact also the opening or response to an email) or until the User requests the deletion of his data by contacting the Data Controller at one of the contact details indicated in this information;
  • in addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority, as if the processing is carried out for administrative/accounting obligations (indeed for 10 years).

At the end of the retention period or at the exhaustion of the purpose for which they were collected, personal data will be deleted. Therefore, at the end of this period, the rights of access, cancellation, rectification and the right to portability of the Data can no longer be exercised.

Purpose of the Processing of collected Data

Your Data is collected to allow the Data Controller to provide its services on this website or directly, as well as for the following purposes:

  • Management of contact data for sending direct email messages or newsletters;
  • Contact you;
  • Statistics;
  • Interaction with social networks;
  • Comment on the articles in this Blog;
  • Interaction with data collection platforms and other third parties;
  • Spam protection;
  • Data transfer outside the EU and site hosting and back-end infrastructure.

To obtain further detailed information on the purposes of the processing and personal data concretely relevant for each purpose, you may refer to the relevant sections of this document.

Details on the processing of Personal Data

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

  • Content commentary

The comment services allow Users to make and make public their own comments regarding the content of this Website.

Users, depending on the settings decided by the Data Controller, can leave the comment also anonymously. If your Personal Data contains the email, it may be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.

In the event that a comment service provided by third parties is installed, it is possible that, even if users do not use the comment service, the same collects traffic data related to the pages on which the comment service is installed.

Directly managed comment system

This Website has its own content commenting system.

Personal data collected: email and name.

  • Contact you

Mailing List or Newsletter (data collected from this Website, and/or from the user, fair or event)

By registering for the mailing list or newsletter, the User’s email address is automatically entered in a list of contacts to which email messages containing information related to the topics covered on this website can be transmitted. Your email address may also be added to this list either as a result of registering for this Website, or after purchasing a service or having had direct relationships with the Data Controller and/or his collaborators.

Personal data collected: email, first name, surname and other contact details.

Contact form (data collected from this Website and/or at the user, fair or event)

The User who has filled in the contact form with his Data both on the site and at the user himself or on other occasions, e.g. fairs or events, consents to their use to respond to requests for information or any other nature indicated by the form header.

Personal data collected: contact data and emails

Contact by phone (through this Website and/or at the user, fair or event)

Users who have provided their phone number both on the website and directly by voice or email, may be contacted for promotional purposes related to this website, as well as to satisfy requests for support, advice or training.

Personal data collected: contact details and phone number.

  • Managing addresses and sending email messages

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the Potential User.

These services may also allow you to collect data relating to the date and time that you view messages, as well as your interaction with them, as well as information about the clicks on the links entered in the messages.

Responsible for the processing of these services is the Data Controller.

  • Hosting and backend infrastructure

This type of service has the function of hosting data and files that allow this Website to function, allow its distribution and provide a ready-to-use infrastructure to provide specific features of this Website.

Some of these services operate through servers geographically located in different locations, making it difficult to determine the exact location where Personal Data is stored.

SiteGround Hosting (SiteGround Hosting Ltd.)

SiteGround Hosting is a hosting service provided by SiteGround Spain S.L. Calle Prim 19 – 28004 Madrid, Spain.

Personal data collected: Cookies, Usage Data and various types of Data as specified by the service’s privacy policy.

  • Interaction with data collection platforms and other third parties

This type of service allows 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 the event that one of these services is installed, it is possible that, even if users do not use the service, the same collects Usage Data related to the pages on which it is installed.

  • Interaction with social networks and external platforms

This type of service allows you to make interactions 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 relating to each social network. In the event that an interaction service with social networks is installed, it is possible that, even if users do not use the service, the same collects traffic data related to the pages on which it is installed.

Twitter button (Twitter, Inc.)

Twitter’s Tweet button and social widgets are interaction services with the Social Network Twitter, provided by Twitter, Inc.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Facebook button (Facebook, Inc.)

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

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Linkedin button (LinkedIn Corporation)

LinkedIn’s button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

YouTube button (Google Inc.)

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

Personal data collected: Usage data.

Place of processing: USA – Privacy Policy.

  • Spam protection

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

Personal data collected: various types of Data as specified by the privacy policy of the service.

Place of processing: United States – Privacy Policy.

  • Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track 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 reviewing the use of this Website, compiling reports and sharing it with other services developed by Google.

Google may use Personal Data to contextualize and personalize your advertising network’s ads.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Third-party links

This website may contain links to third-party sites not controlled by the Data Controller and that do not operate according to the Privacy Practices of the Data Controller himself. When you link to third-party sites, the practices contained in this privacy are no longer applicable. Please review the privacy policy of each third-party site before using personally identifiable information.

  • Data transfer outside the EU

The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all non-EU countries) only in accordance with a specific legal basis. Therefore, such data transfers are carried out according to one of the legal bases described below.

The User may request information from the Data Controller regarding the legal basis applicable concretely applicable to each individual service.

Transfer of data to countries that guarantee European standards

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision taken by the European Commission. The European Commission takes adequacy decisions with reference to individual third countries that it considers to guarantee a level of protection of Personal Data comparable to that provided for by European legislation on the protection of Personal Data. The User can view the updated list of adequacy decisions on the European Commission’s website.

Data transfer based on standard CCS contractual clauses

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place following an agreement that meets the EU requirements for the transfer of personal data to data controllers or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.

In this regard, it is specified that the transfer of data to the USA for the services and purposes listed above (e.g. Mailchimp for the Newsletter service) takes place on the basis of the standard contractual clauses to which the provider adheres indicated in the specific privacy policy and DPA (Data Process Agreement).

Transfer of Data based on explicit consent expressed by the user for a certain purpose

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place following explicit consent expressed by the user according to one or more specific purposes.

User rights

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

In case of superior protection, you may exercise all of the following rights. In any other case, the User can contact the owner to find out which rights are applicable in his case and how to exercise them.

In particular, you have the right to:

  • withdraw consent at all times. You may withdraw your consent to the processing of your personal data previously expressed.
  • to oppose the processing of its Data. You may object to the processing of your Data when it takes place on a legal basis other than consent. Further details on the right of objection are given in the section below.
  • access to 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.
  • check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.
  • to obtain the limitation of treatment. When certain conditions apply, you may request the limitation of the processing of your 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 your Personal Data. When certain conditions are met, the User may request the cancellation of his Data by the Data Controller.
  • receive their Data or have them transferred to another data controller. You have the right to receive your Data in structured format, common use and readable by automatic device and, where technically feasible, to obtain its transfer without obstacles to another data controller. 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. You may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details of the right of objection

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

Please note to users that, if their Data are processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out if the Data Controller treats data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise your rights, Users may address a request to the Contact Details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cybersecurity

The Data Controller, in line with the provisions of recital 49 of the GDPR, treats, also through its suppliers (third parties and/or recipients), the personal data of the Data Subject relating to traffic to a strictly necessary and proportionate extent to ensure the security of networks and information, i.e. the ability of a network or information system to withstand, at a given level of security, unforeseen events or unlawful or malicious acts that compromise the availability, authenticity, integrity and confidentiality of personal or transmitted data.

The Data Controller will promptly inform the Interested Parties, if there is a particular risk of violation of their data without prejudice to the obligations deriving from the provisions of art. 33 of the GDPR relating to notifications of personal data breach.

COOKIE POLICY OF THE WWW.LIFEEL.EU

Learn more about Cookies

Cookies consist of portions of code installed within the browser that assist the Data Controller in the provision of the Service according to the purposes described. Some of the purposes of installing cookies may also require your consent.

In accordance with the judgment of the Court of Justice of the European Union C-673/17 on the use of cookies and the “Guidelines 05/2020 on consent pursuant to Regulation 2016/679”, adopted by the European Committee for Data Protection, consent to the use of cookies must be given in a free, express and non-ambiguous manner. For this reason, the Site activates the use of cookies only in the event that the User clicks on the “I accept cookies” button, included in the banner that appears on the first access to the Site. In the event that you wish to configure or change your cookie settings, you can access this extended policy. To change the cookie settings in a more granular way, the User can use the link www.youronlinechoices.eu already indicated in the banner that appears at the first access and follow the instructions indicated therein. The Site uses different types of cookies for different purposes: necessary technical cookies and aggregate statistics (analytics), cookies for the optimization of features and statistics and profiling cookies. Some cookies may be provided by external third parties to integrate additional features to our Site as follows.

Technical cookies and aggregate statistics (analytics)

Activities strictly necessary for operation

This Website uses Cookies to save your session and to perform other activities strictly necessary for the operation of this Website and cannot be deactivated in our systems. If you refuse these cookies, by modifying your browser information, we cannot guarantee the operation and performance of our Site during your visit.

Preference saving, optimization, and statistics tasks

This Website uses Cookies to save your browsing preferences and optimize your browsing experience.

These are cookies that allow us to collect information about the number of visitors to the Site and how they visit the Site itself, which websites they come from and which are the most popular pages so that we can measure and improve the performance of our Site. All this information is collected through cookies in anonymized aggregate form. If you do not consent to these cookies, we will not know when you have visited our Site and we will not be able to optimize the content to provide you with a better browsing experience.

Other types of cookies or third-party tools that may install

Some of the services listed below collect statistics in aggregate and anonymous form and may not require your consent or may be managed directly by the Data Controller – as described – without the help of third parties.

If among the tools indicated below there are services managed by third parties, they may – in addition to what is specified and also without the Knowledge of the Data Controller – carry out user tracking activities. For detailed information, please refer to the privacy policies of the services listed.

Interaction with social networks and external platforms

This type of service allows you to make interactions 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 relating to each social network.

In the event that an interaction service with social networks is installed, it is possible that, even if users do not use the service, the same collects traffic data related to the pages on which it is installed.

Twitter Tweets and Social Widgets button (Twitter, Inc.)

Twitter’s Tweet button and social widgets are interaction services with the Social Network Twitter, provided by Twitter, Inc.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Facebook Likes and Social Widgets button (Facebook, Inc.)

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

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Linkedin button and social widgets (LinkedIn Corporation)

LinkedIn’s button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Statistics and profiling

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track the User’s behavior to optimize his advertising investments and to provide the user with advertising that is more in keeping with his interests and as repetitive as possible.

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 reviewing the use of this Website, compiling reports and sharing it with other services developed by Google.

Google may use Personal Data to contextualize and personalize your advertising network’s ads.

Personal data collected: anonymized IP, device type, geographical area and other types of data.

Place of processing: USA – Privacy Policy – Opt Out.

How can I consent to the installation of Cookies?

In addition to what is indicated in this document, the User can manage cookie preferences directly within his browser and prevent – for example – that third parties can install them. Through the browser preferences it is also possible to delete cookies installed in the past, including the Cookie in which consent to the installation of Cookies by this site is possibly saved. You may find information on how to manage Cookies with some of the most popular browsers, for example at the following addresses:

Google Chrome,

Mozilla Firefox,

Apple Safari

Microsoft Internet Explorer.

With reference to Cookies installed by third parties, you can also manage your settings and revoke your consent by visiting the relevant opt out link (if available), using the tools described in the third party’s privacy policy or contacting you directly.

You can manage your preferences on cookies to be activated or deactivated in a more granular way by going to the www.youronlinechoices.eu

Without prejudice to the foregoing, you may avail you of the information provided by EDAA (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services you can manage tracking preferences of most advertising tools. The Data Controller therefore advises Users to use these resources in addition to the information provided by this document.

Data Controller

Cesare Mario Puzzi

Via Repubblica 1 – 21020 Varano Borghi (VA) – Italy

Owner’s email address: cesare.puzzi@graia.eu

Since the installation of Cookies and other tracking systems operated by third parties through the services used within this Website cannot be technically controlled by the Data Controller, any specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. To obtain complete information, you are invited to consult the privacy policy of any third-party services listed in this document.

Given the objective complexity of identifying cookie-based technologies, the User is invited to contact the Data Controller if he wishes to receive any further information related to the use of cookies through this Website.

Definitions and legal references

Personal Data (or Data)

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, shall constitute personal data.

Usage data

This is the information automatically collected through this Website (including from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, addresses in Uniform Resource Identifier (URI) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (good end, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (e.g. the time of stay on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted , parameters related to the user’s operating system and IT environment.

User

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

Interested

The natural person to whom personal data relates.

Data Controller (or Manager)

The natural, legal, public administration and any other entity that treats personal data on behalf of the Data Controller, 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 tools adopted, including security measures relating 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 Your Personal Data is collected and processed.

Service

The Service provided by this Website as defined in its 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 portion of data stored inside the User’s device.

Legal references

This privacy policy is written on the basis of multiple legislative regulations, including art. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies only to this Website.

Last modified: March 23, 2021