Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your Personal Data is Haruspex S.R.L. of Via Vittorio Veneto, 126, 19124, La Spezia (SP), Italy.
Owner of Personal Data: Marcello Montecucco, email@example.com.
Data Protection Officer (DPO): Federico Tonelli, firstname.lastname@example.org.
Privacy and Our Customers: This Policy does not apply to the extent we process Personal Data provided by our customers through the provision of services and use of our products. For detailed privacy information related to instances where a customer and/or a customer affiliate that uses our products and services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Policy. For more information, please also see section 13 below.
Changes to this Policy: We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Site prior to such changes(s) taking effect. We encourage you to periodically review this Policy to stay informed about our collection, processing, and sharing of your Personal Data.
1. Purposes of Processing
What is Personal Data?
We may collect information about you as set out in this Policy and that may include Personal Data. Personal Data may include: full name, company name, job title, email address, contact phone, area of interest, country, and information collected through cookies and other similar technologies.
Why do we need your Personal Data?
We will only collect and/or process your Personal Data in compliance with applicable data protection and privacy laws and in accordance with this Policy. In order to provide you with access to the Site, we may process your Personal Data in accordance with this Policy. If you create a profile or register with us, you will be asked to agree to provide certain information in order to access our services or view our content. By agreeing to do so you consent to your Personal Data being processed by us. This consent provides us with the legal basis to process your Personal Data. If you change your mind and wish to withdraw your consent to us processing your Personal Data, you may withdraw your consent at any time. If you do not agree to our use of your Personal Data in line with this Policy, please do not use our Site.
2. Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This may include:
- any Personal Data you provide to us, including name, postal address, email address, telephone number, and a username;
- any Personal Data that may be contained in any video, comment, or other submission you upload or post to the Site;
- any Personal Data you provide when you report a problem with our Site or when we provide you with technical support for your evaluation license;
- any Personal Data you provide when you make a purchase through our Site;
- any Personal Data you provide when you correspond with us by phone, email, or otherwise.
Information from Social Networking Sites. Our Site includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Site, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when visiting our Site, we identify an initial public IP address to identify where you are located, we log your computer or mobile device operating system name and version, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you by using cookies. Please refer to the sections on cookies, flash technology and pixel tags below.
Automated Decision Making and Profiling. We may use automated decision making and/or profiling in regard to your Personal Data for some services and products, for example, when logging into Haruspex’s Community, Haruspex will need to identify if you are a customer or not, or messaging may change depending on your prior visits to our site. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision making and/or profiling by contacting us at email@example.com.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our site uses the following types of cookies for the purposes set out below:
Type of cookie
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
Targeted and advertising cookies
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.
You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/ or http://optout.aboutads.info/. If you choose to remove targeted or advertising cookies, you will still see advertisements, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on [our Site/Application(s)/Services] or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
4. Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site to track the actions of users on our Site. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ Personal Data.
5. Using Your Personal Data
We may use your Personal Data as follows:
- to operate, maintain, and improve our Site;
- to evaluate your registration on our Site;
- to deliver the services you request and manage your account, including to communicate with you regarding your account on our Site or your evaluation license;
- to respond to your comments and questions;
- to send information including technical notices, updates, security alerts, and support and administrative messages regarding our Site or your evaluation license;
- to send you marketing communications, including via e-mail in compliance with applicable laws, about upcoming promotions, newsletters, new products, services, webinars, training seminars and other news, including information about products and services offered by us and our affiliates;
- to link or combine user information with other Personal Data;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce this Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
6. Sharing Your Personal Data
We may share Personal Data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
7. Anonymous Data
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data for our own purposes, including the ability to analyze usage patterns in order to make improvements to our Site.
8. Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them. For example, we may link to social media pages through widgets on our Site or we may provide links to industry reports.
9. User Generated Content
You may share Personal Data with us when you submit user generated content to our Site. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public. We urge you to be very careful when deciding to disclose your Personal Data, or any other information, on our Site. Such Personal Data and other information will not be private or confidential once it is published on our Site.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 16 below.
We will retain your Personal Data for a period of time consistent with the original purpose of collection (see Section 5, “Using Your Personal Data”). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, we will delete your Personal Data. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
12. Our Policy on Children
We respect the sensitive nature of children’s privacy online. Our Site is not directed to children under 16 and we do not knowingly collect Personal Data from children under the age of 16. You must be at least sixteen (16) years old to register, purchase or apply online for our products, services, promotions and other activities. If you are under the age of sixteen (16), please do not provide us with any type of information about yourself. Haruspex is not liable for any information provided to us by a person under the age of sixteen (16).
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at firstname.lastname@example.org. We will delete such information from our systems as soon as reasonably practicable.
13. Your Rights
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws, and, in particular, if you are located in the EEA, these rights may include:
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive Personal Data; (iv) any new processing of your Personal Data that we may carry out beyond the original purpose; or (v) the transfer of your Personal Data outside the EEA. Please note that your use of some of the Site may be ineffective upon opt-out.
- You may request what access Haruspex has about you at any time by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your Personal Data.
- Your Personal Data is portable – i.e., you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of the rights set forth above, please contact us using the details in Section 15 below. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the above rights you would like to exercise. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes, legal purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Your Rights Relating to Customer Data
As described above, we may also process Personal Data submitted by or for a customer of our products and services. To this end, if not addressed in this Policy or in a separate disclosure, we process such Personal Data in our role as processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Policy. If your data has been submitted to us by or on behalf a Haruspex customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. If you wish to make your request directly to us, please provide to us the name of the Haruspex customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
Your Preferences for Email Communications
If you prefer not to receive promotional materials, our email newsletter or other forms of communication, you may choose to opt-out or manage your email subscriptions by sending an email at email@example.com. Haruspex will honor your requests to opt-out of specified emails and marketing materials. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements, or security information.