Privacy Policy

Privacy Policy of Cleofe Finati
Cleofe Finati collects some Personal Data from its Users.

Personal Data collected for the following purposes and using the following services:
Access to third party services’ accounts
Facebook account access
Permissions: Contact email

Access to the Twitter account, Stripe account access and Google Drive account access
Personal Data: various types of Data as specified in the privacy policy of the service

Analytics
Google Analytics, Google Ads conversion tracking, Facebook Ads conversion tracking (Facebook pixel), Google Tag Manager, Twitter Ads conversion tracking, Yahoo Advertising conversion tracking, Display Advertising extension for Google Analytics, KISSmetrics, WordPress Stats, HubSpot Analytics, LinkedIn conversion tracking, Salesforce Analytics Cloud and Google Analytics with anonymized IP
Personal Data: Cookies; Usage Data

User ID extension for Google Analytics
Personal Data: Cookies

Facebook Analytics for Apps
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Commercial affiliation
ReferralCandy
Personal Data: Cookies; email address; first name; last name; Usage Data

Content commenting
Comment system managed directly
Personal Data: Cookies; email address; first name; last name

Disqus
Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

Data transfer outside the EU
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield, Data transfer to countries that guarantee European standards, Data transfer abroad based on consent, Data transfer abroad based on standard contractual clauses and Other legal basis for Data transfer abroad
Personal Data: various types of Data

Displaying content from external platforms
Google Fonts
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

Google Maps widget, Vimeo video, Instagram widget and YouTube video widget
Personal Data: Cookies; Usage Data

Hosting and backend infrastructure
Amazon Web Services (AWS)
Personal Data: various types of Data as specified in the privacy policy of the service

Interaction with data collection platforms and other third parties
Mailchimp widget
Personal Data: Cookies; email address; first name; last name

Interaction with live chat platforms
Facebook Messenger Customer Chat
Personal Data: About Me; Cookies; Data communicated while using the service; Usage Data

Freshchat Widget
Personal Data: Cookies; Data communicated while using the service; email address; Usage Data

Managing contacts and sending messages
Mailchimp, MailUp and ZOHO Campaigns
Personal Data: email address

HubSpot Email
Personal Data: email address; Usage Data

Managing support and contact requests
Freshdesk, Salesforce Service Cloud and ZOHO CRM Email
Personal Data: various types of Data as specified in the privacy policy of the service

Registration and authentication
Facebook Authentication, Twitter OAuth, Google OAuth, Log In with PayPal, Login with Amazon, Mailchimp OAuth, Stripe OAuth, Linkedin OAuth and Instagram Authentication
Personal Data: various types of Data as specified in the privacy policy of the service

Direct registration
Personal Data: address; email address; first name; last name; password; phone number

Social features
Inviting and suggesting friends
Personal Data: Various types of Data

User database management
FullContact
Personal Data: company name; date of birth; Email; first name; gender; last name; various types of Data as specified in the privacy policy of the service

HubSpot CRM
Personal Data: email address; phone number; various types of Data as specified in the privacy policy of the service

HubSpot Lead Management, Salesforce Marketing Cloud and Salesforce Sales Cloud
Personal Data: various types of Data as specified in the privacy policy of the service

ZOHO CRM
Personal Data: email address; various types of Data as specified in the privacy policy of the service

Advertising
Direct Email Marketing (DEM)
Personal Data: email address

Microsoft Advertising, Criteo, Ligatus, Tradedoubler, Google Ad Manager, Yahoo App Publishing Advertising, Rai Pubblicità, RCS MediaGroup Advertising and IlSole24Ore Advertising
Personal Data: Cookies; Usage Data

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

Facebook Audience Network
Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

Backup saving and management
Backup on Google Drive and Backup on Dropbox
Personal Data: various types of Data as specified in the privacy policy of the service

Contacting the User
Mailing List or Newsletter
Personal Data: email address

Phone contact
Personal Data: phone number

Contact form
Personal Data: address; city; company name; country; date of birth; email address; field of activity; first name; gender; last name; phone number; profession; Tax ID; User ID; various types of Data; VAT Number; ZIP/Postal code

Content performance and features testing (A/B testing)
Google Optimize
Personal Data: Cookies; Usage Data

Device permissions for Personal Data access
Device permissions for Personal Data access
Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; Calendar permission; Camera permission; Contacts permission; HomeKit permission; Microphone permission; Motion sensors permission; Phone permission; Precise location permission (continuous); Precise location permission (non-continuous); Reminders permission; Sensors permission; SMS permission; Social media accounts permission; Storage permission

Handling payments
PayPal, Klarna, SOFORT, Stripe, Apple Pay, Amazon Payments and PayPal Payments Hub
Personal Data: various types of Data as specified in the privacy policy of the service

PayPal Carrier Payments
Personal Data: phone number; various types of Data as specified in the privacy policy of the service

Infrastructure monitoring
Pingdom
Personal Data: Cookies; Usage Data

Interaction with external social networks and platforms
PayPal button and widgets, Facebook Like button and social widgets, LinkedIn button and social widgets, Google+ +1 button and social widgets and Twitter Tweet button and social widgets
Personal Data: Cookies; Usage Data

Location-based interactions
Geolocation
Personal Data: geographic position

Managing landing and invitation pages
Mailchimp Landing Page
Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username

Leadpages
Personal Data: email address; Usage Data; various types of Data as specified in the privacy policy of the service

Platform services and hosting
Shopify, Tumblr and WordPress.com
Personal Data: various types of Data as specified in the privacy policy of the service

Remarketing and behavioral targeting
Facebook Remarketing, AdRoll, Remarketing with Google Analytics, Google Ads Remarketing, Twitter Remarketing, Google Ad Manager Audience Extension, Criteo Dynamic Retargeting and LinkedIn Website Retargeting
Personal Data: Cookies; Usage Data

Facebook Custom Audience and Twitter Tailored Audiences
Personal Data: Cookies; email address

SPAM protection
Google reCAPTCHA
Personal Data: Cookies; Usage Data

Further information about Personal Data
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Cleofe Finati depends on the payment system used.

Unique device identification
Cleofe Finati may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

User identification via a universally unique identifier (UUID)
Cleofe Finati may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Cleofe Finati to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Personal Data collected through sources other than the User
The Owner of Cleofe Finati may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Privacy Shield participation: data transfers from the EU and Switzerland to the United States
The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

What does this mean for the European User?

The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution under the Privacy Shield

In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Cleofe Finati may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Cleofe Finati adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

to enable or otherwise improve the decision-making process;
to grant Users fair and unbiased treatment based on consistent and uniform criteria;
to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Cleofe Finati, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
Contact information
Owner and Data Controller
Archetipo Srl
Via Tavagnacco 89/b, 33100, Udine, Italia
P. IVA: 01745980308

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