Privacy Policy | Ettore Poggipollini - Ettore Poggipollini | Official Site

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Latest update: October 21, 2020


Ettore Poggipollini collects some Personal Data from its Users.

This document contains a section dedicated to:

  • Californian consumers and their privacy rights.

  • Brazilian Users and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.




Owner and Data Controller
Ettore Poggipollini

Owner contact email:
et@ettorepoggipollini.com




Types of Data collected

Among the types of Personal Data that Ettore Poggipollini collects, by itself or through third parties, there are: first name; email address; Cookies; Usage Data.

Complete  details on each type of Personal Data collected are provided in the  dedicated sections of this privacy policy or by specific explanation  texts displayed prior to the Data collection.

Personal  Data may be freely provided by the User, or, in case of Usage Data,  collected automatically when using Ettore Poggipollini.

Unless  specified otherwise, all Data requested by Ettore Poggipollini is  mandatory and failure to provide this Data may make it impossible for  Ettore Poggipollini to provide its services. In cases where Ettore  Poggipollini 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.

Any  use of Cookies – or of other tracking tools – by Ettore Poggipollini or  by the owners of third-party services used by Ettore Poggipollini  serves the purpose of providing the Service required by the User, in  addition to any other purposes described in the present document and in  the Cookie Policy, if available.

Users  are responsible for any third-party Personal Data obtained, published  or shared through Ettore Poggipollini 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 Ettore Poggipollini (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.

Place

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.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • 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  Service, comply with its legal obligations, respond to enforcement  requests, protect its rights and interests (or those of its Users or  third parties), detect any malicious or fraudulent activity, as well as  the following: Contacting the User, Analytics and Displaying content  from external platforms.

For  specific information about the Personal Data used for each purpose, the  User may refer to the section “Detailed information on the processing  of Personal Data”.



Detailed information on the processing of Personal Data

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

  • Analytics

The  services contained in this section enable the Owner to monitor and  analyze web traffic and can be used to keep track of User behavior.

  • Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited  (“Google”). Google utilizes the Data collected to track and examine the use of Ettore Poggipollini, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out. Privacy Shield participant.
This  type of service analyzes the traffic of Ettore Poggipollini,  potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  • Anonymized analytics services

The services contained in this section are third-party services that enable the Owner, through the use of Cookies and other Identifiers, to manage third-party analytics in an anonymized form. Depending on the applicable law these services may not require Users to consent.

In such cases Users can disable the Identifiers by modifying their browser or device settings as described in more detail within this document

  • Google Analytics with anonymized IP (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data processed: Cookies and Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out. Privacy Shield participant.


  • SPAM protection

  • Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

  • 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 services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  • Hosting Service provided by Aruba (Aruba S.p.A.)

Aruba is an hosting service provided by Aruba S.p.a.

Personal Data processed: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Italy

  • Contacting the User

  • Contact form (Ettore Poggipollini)

By  filling in the contact form with their Data, the User authorizes Ettore  Poggipollini 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 processed: email address; first name.

  • Displaying content from external platforms

This  type of service allows you to view content hosted on external platforms  directly from the pages of Ettore Poggipollini and interact with them.
This  type of service might still collect web traffic data for the pages  where the service is installed, even when Users do not use it.

  • YouTube video widget (Google LLC)

YouTube  is a video content visualization service provided by Google LLC that  allows Ettore Poggipollini to incorporate content of this kind on its  pages.
Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • Font Awesome (Fonticons, Inc. )

Font  Awesome is a typeface visualization service provided by Fonticons, Inc.  that allows Ettore Poggipollini to incorporate content of this kind on  its pages.
Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

  • Google Fonts (Google Ireland Limited)

Google  Fonts is a typeface visualization service provided by Google Ireland  Limited that allows Ettore Poggipollini to incorporate content of this  kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Category of personal data collected according to CCPA: internet information.

This  processing constitutes a sale based on the definition under the CCPA.  In addition to the information in this clause, the User can find  information regarding how to opt out of the sale in the section  detailing the rights of Californian consumers.

  • Handling payments

  • PayPal

Payment processing services enable Ettore Poggipollini to process payments by credit card, bank transfer or other means.

To ensure greater security, Ettore Poggipollini 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.

  • PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Category of personal data collected according to CCPA: internet information.

  • Braintree (PayPal (Europe) S.a.r.l. et Cie, S.C.A.)

Braintree is a payment service provided by Braintree, a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.
Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the Braintree privacy policy – Privacy Policy.

Category of personal data collected according to CCPA: internet information.

  • Traffic optimization and distribution

This  type of service allows Ettore Poggipollini to distribute their content  using servers located across different countries and to optimize their  performance.

Which Personal Data are processed depends on the  characteristics and the way these services are implemented. Their  function is to filter communications between Ettore Poggipollini and the  User's browser.

Considering the widespread distribution of this  system, it is difficult to determine the locations to which the contents  that may contain Personal Information of the User are transferred.

  • Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

The  way Cloudflare is integrated means that it filters all the traffic  through Ettore Poggipollini, i.e., communication between Ettore  Poggipollini and the User's browser, while also allowing analytical data  from Ettore Poggipollini to be collected.

Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal data collected according to CCPA: internet information.

This  processing constitutes a sale based on the definition under the CCPA.  In addition to the information in this clause, the User can find  information regarding how to opt out of the sale in the section  detailing the rights of Californian consumers.

  • Interaction with external social networks and platforms

  • PayPal button and widgets (PayPal Inc.)

The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: See the PayPal privacy policy



The rights of Users

Users may exercise certain rights regarding their Data processed by Ettore Poggipollini.
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 Ettore Poggipollini, 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, Ettore Poggipollini 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 Ettore Poggipollini.
  • 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.



Cookies Policy

Ettore Poggipollini uses Cookies and other Identifiers. To learn more, the User can consult the Cookies Policy.




Additional information about Data collection and processing

Legal action

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 Ettore Poggipollini 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

In addition to the information contained in this privacy policy, Ettore Poggipollini may provide the User with additional and contextual information concerning particular Services or the collection and  processing of Personal Data upon request.

System logs and maintenance

For  operation and maintenance purposes, Ettore Poggipollini and any  third-party services may collect files that record interaction with Ettore Poggipollini (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

Ettore Poggipollini 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.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any  time by notifying its Users on this page and possibly within Ettore Poggipollini and/or - as far as technically and legally feasible -  sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

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.

Usage Data

Information collected automatically through Ettore Poggipollini (or third-party  services employed in Ettore Poggipollini), which can include: the IP addresses or domain names of the computers utilized by the Users who use Ettore Poggipollini, 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 Site) and the  details about the path followed within the Site 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

The individual using Ettore Poggipollini who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The  natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in  this privacy policy.

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 Ettore Poggipollini. The Data Controller,  unless otherwise specified, is the Owner of Ettore Poggipollini.

Ettore Poggipollini (or this Site/Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Ettore Poggipollini 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.

Cookies
Small sets of data stored in the User's device.

Legal information

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).

This privacy policy relates solely to Ettore Poggipollini, if not stated otherwise within this document.




Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Ettore Poggipollini and, if the case may be, its  parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are  consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such  consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In  this section we summarize the categories of personal information that  we've collected, disclosed or sold and the purposes thereof. You  can read about these activities in detail in the section titled  “Detailed information on the processing of Personal Data” within this  document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: internet information.
We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Ettore Poggipollini.
For example, you directly provide your personal information when you submit requests via any forms on Ettore Poggipollini. You also provide personal information indirectly when you navigate Ettore Poggipollini,  as personal information about you is automatically observed and  collected. Finally, we may collect your personal information from third  parties that work with us in connection with the Service or with the  functioning of Ettore Poggipollini and features thereof.

How we use the information we collect

Sharing and disclosing of your personal information with third parties for a business purpose.

We may disclose the personal information we collect about you to a third  party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the  personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For  our purposes, the word “sale” means any “selling, renting, releasing,  disclosing, disseminating, making available, transferring or otherwise  communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This  means that, for example, a sale can happen whenever an application runs  ads, or makes statistical analyses on the traffic or views, or simply  because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You  have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we  will abide by your request.
Such requests  can be made freely, at any time, without submitting any verifiable  request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Ettore Poggipollini, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of Ettore Poggipollini  and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and  strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed  information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

  • the  categories and sources of the personal information that we collect  about you, the purposes for which we use your information and with whom  such information is shared;
  • in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • for sales, the personal information categories purchased by each category of recipient; and
    • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will  be "portable", i.e. delivered in an easily usable format to enable you  to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as,  including but not limited to, where the information is used to identify  and repair errors on Ettore Poggipollini, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we  will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To  exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this  document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We  will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a  person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We  will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90  days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases,  we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons  behind it.



Information for Users residing in Brazil

This part of the document integrates with and supplements the information  contained in the rest of the privacy policy and is provided by the  entity running Ettore Poggipollini and, if the case may be, its parent, subsidiaries and affiliates (for  the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are  referred to below, simply as “you”, “your”, “yours”).
For such Users,  these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

  • your consent to the relevant processing activities;
  • compliance with a legal or regulatory obligation that lies with us;
  • the  carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymized personal information;
  • the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
  • the exercising of our rights in judicial, administrative or arbitration procedures;
  • protection or physical safety of yourself or a third party;
  • the protection of health – in procedures carried out by health entities or professionals;
  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
  • credit protection.

To find out more about the legal bases, you can contact Ettore Poggipollini at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To  find out why we process your personal information, you can read the  sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:
  • obtain confirmation of the existence of processing activities on your personal information;
  • access to your personal information;
  • have incomplete, inaccurate or outdated personal information rectified;
  • obtain  the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
  • obtain information on the possibility to provide or deny your consent and the consequences thereof;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product  provider, provided that our commercial and industrial secrets are  safeguarded;
  • obtain the  deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
  • revoke your consent at any time;
  • lodge  a complaint related to your personal information with the ANPD (the  National Data Protection Authority) or with consumer protection bodies;
  • oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • request  the review of decisions made solely on the basis of the automated  processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You  can file your express request to exercise your rights free from any  charge, at any time, by using the contact details provided in this  document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to  communicate to you the factual or legal reasons that prevent us from  immediately, or otherwise ever, complying with your requests. In cases  where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request,  please make sure that you specify whether you’d like your personal  information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified  fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your  personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other  parties with whom we have shared your personal information in order to  enable such third parties to also comply with your request – except in  cases where such communication is proven impossible or involves  disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to  the legal means provided by the international law;
  • when the transfer is necessary to protect your life or physical security or those of a third party;
  • when the transfer is authorized by the ANPD;
  • when the transfer results from a commitment undertaken in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal attribution of public service;
  • when  the transfer is necessary for compliance with a legal or regulatory  obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

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