Privacy Policy

Privacy Policy of

This site collects some Personal Data from its Users.

Usersmay be subject to different protection standards and broader standards maytherefore apply to some. In order to learn more about the protection criteria,Users can refer to the applicability section.

Types of Data collected

the types of Personal Data that this Application collects, by itself or through
third parties, there are: Cookies, Usage Data and email address.

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 this Application.
Unless specified otherwise, all Data requested by this Application is mandatory
and failure to provide this Data may make it impossible for this Application to
provide its services. In cases where this Application 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 this Application or by the
owners of third-party services used by this Application 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.

are responsible for any third-party Personal Data obtained, published or shared
through this Application 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

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 this
Application (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

Owner may process Personal Data relating to Users if one of the following

  • 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
  • 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.


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.

broader protection standards are applicable, 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

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


  • 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.

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

The purposes of processing

Data concerning the User is collected to allow the Owner to provide its Services,
as well as for the following purposes: Analytics, Content commenting and
Content performance and features testing (A/B testing).

can find further detailed information about such purposes of processing and
about the specific Personal Data used for each purpose in the respective
sections of this document.

Detailed information on the processing of
Personal Data

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

  • Analytics
  • Content commenting
  • Content performance and features testing (A/B testing)

The rights of Users

may exercise certain rights regarding their Data processed by the Owner.

entitled to broader protection standards may exercise any of the rights
described below. In all other cases, Users may inquire with the Owner to find
out which rights apply to them.

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 the Owner, 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, the
    Owner 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 the Owner.
  • Receive their Data and have it transferred to another
    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

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

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

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.

Applicability of broader protection standards

most provisions of this document concern all Users, some provisions expressly
only apply if the processing of Personal Data is subject to broader protection

broader protection standards apply when the processing:

  • is performed by an Owner based within the EU;
  • concerns the Personal Data of Users who are in the EU
    and is related to the offering of paid or unpaid goods or services, to such
  • concerns the Personal Data of Users who are in the EU
    and allows the Owner to monitor such Users’ behavior taking place in the EU.

Additional information about Data collection and

Legal action

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 this
Application 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

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

System logs and maintenance

operation and maintenance purposes, this Application and any third-party
services may collect files that record interaction with this Application
(System logs) use other Personal Data (such as the IP Address) for this

Information not contained in this policy

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

Application 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

Owner reserves the right to make changes to this privacy policy at any time by
giving notice to its Users on this page and possibly within this Application
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