Privacy policy – update May 2018

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Dear reader, welcome to GG Giovani Genitori privacy notice

GG Giovani Genitori – a newspaperedited from Espressione srl –  respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit and use our websites (www.giovanigenitori.it and our related websites) (“Website”) or our GG Giovani Genitori branded app (“App”) and tells you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how GG Giovani Genitori collects and processes your personal data through your use of our Website or App, including any data you may provide through our Website or App when you sign up to our newsletter or set-up a user account.

The Website and App are not intended for children (i.e. individuals aged 18 or under) and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices we give and is not intended to override them.

Controller

Espressione srl is the controller and responsible for your personal data (referred to as “Espressione”, “we”, “us” or “our” in this privacy notice).

Espressione is responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Espressione is the controller and responsible for the Website and App.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager.

Contact details

Our full details are:

Full name of legal entity: Espressione srl

Email address: privacy@espressione.it

Postal address: Via Vanchiglia 18 – 10124 Torino Italia

You have the right to make a complaint at any time, and we hope not because we operate with responsability and honest behaviour. We hope that in any case you will contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This privacy policy was last updated on 24/05/2018 and historic versions can be obtained by contacting us using the contact details in the paragraph above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The Website and App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website or app you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below.

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, age and gender, your photograph (where you sign-up to an account with us and choose to include your picture on your account).
  • Contact Data includes email address and telephone numbers
  • Technical Data includes mobile device ID (when using our App), internet protocol (IP) address), your login data, browser type (for website use), time zone setting and location, operating system and platform and other technology related information about the devices you use to access the Website or App. If you use our Website or App from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS to identify your precise location
  • Profile Data includes your username and password, your location, feedback and survey responses. When you log in with us via Facebook, we will receive (unless you change your settings within Facebook), your public profile information (i.e. your name and profile picture), your birth date, a list of your friends which also use the App and your current city listed in your Timeline
  • Usage Data includes information about how you use the Website or App (including your content viewing habits), products and services.
  • Marketing includes your preferences in receiving marketing from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or App feature or content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • contact us regarding products or services we offer on our Website or App;
    • create an account on our Website or App;
    • subscribe to our newsletter;
    • opt-in to receiving marketing emails from us;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you use the Website or App we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. 

  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

    • Technical Data from the following parties:

      • analytics providers such as Google, Facebook and Salesforce DMP to collect standard internet log information and details of Website visitors’ behavior patterns.
      • affiliate networks (such as Amazon UK, Amazon US, AvantLink, Commission Junction, Performance Horizon, Rakuten, Skimlinks, Affiliate Window, Viator, Affilinet, Impact Radius, Webgains, Tradedoubler, Viglink) where you click on an affiliate link featured in our content.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To allow you to open an account via our Website or App

(a) Identity

(b) Contact

(c) Profile

Necessary for our legitimate interests to offer a better service and user experience

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c) Responding to your queries or complaints regarding the Website or App

(a) Identity

(b) Contact

(c) Profile

(d) Marketing

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to respond to user’s questions on the use of our Website or App)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant App and Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to provide a good experience to our users, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Website, App, products/services, provision of content, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services or content that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To track your viewing habits and engagement with affiliate links and adverts on the Website and App

(a) Technical

(b) Usage

Necessary for our legitimate interests to develop and grow our business

5. opting out of personalised content and adverts

So that we can provide you with a great user experience, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need. This is how we decide which adverts and content may be relevant for you. You will only receive marketing communications from us by email if you provided us with your express opt-in consent.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and providing you with personalized content. We have established the following personal data control mechanisms:

How to opt- out of a personalised website or app experience

Opting out for App Users:

If you do not want your experience on the App to be tailored to you based on your viewing habits on the App, go to your profile->settings and slide the ‘Personalisation’ to ‘Off’. If you change your mind and would like to receive a personalised experience, you can simply slide the ‘Personalisation’ button back to ‘On’.

Opting out for Website users who are logged into their Culture Trip Account:

If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, go to profile->settings and uncheck the ‘Personalisation’ checkbox. If you change your mind and would like to receive a personalised experience, you can simply re-check the box.

Opting out for Website users who do not have a Culture Trip Account:

If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, please to opt out from personalisation. If you change your mind and would like to receive a personalised experience, you can simply write us here. If you click the link to opt-out, we will place a ‘do not track’ cookie on your browser. Please note that if you delete all cookies on your browser, or if you use a different browser to access the Website you will have to click this link again in order to stop us personalising your experience on our Website.

Marketing emails

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time: privacy@espressione.it.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We do not share your personal data with third parties services.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

7. International transfers

We share your personal data within Espressione. This will involve transferring your data outside the European Economic Area (EEA).

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We retain your personal data while your account is in existence or as needed to provide you the Website and App. This includes data you or others provided to us and data generated or inferred from your use of our Website or App.

In some circumstances you can ask us to delete your data: please write us for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your legal rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you request correction, erasure or restriction about your personal data, please contact us.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

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