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This Privacy Policy ("Policy") describes how Sealo S.r.l. and its affiliates ("Sealo," "we," or "our") collect, use, disclose, and retain personal data from individuals interacting with any website, mobile site, application, marketing campaign, event, email, newsletter, and other online or offline activities, offers, or publications that link to or reference this Policy (collectively, the "Services"). This Policy also describes the rights that users may have regarding the processing of their personal data under applicable local law.
By accessing or using any of our Services, the user acknowledges and agrees that their personal information will be processed as described in this Policy. The user’s use of the Services and any disputes concerning privacy are subject to this Policy and our User Terms and Conditions, including applicable liability limitations and dispute resolution procedures.
Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a user. Depending on the Services used by the user, we may collect the following categories of personal information directly from the user, automatically through the use of the Services, and from third parties:
We collect personal information directly from you when you use our Services, such as when you provide us with information online or during an in-person event (e.g., uploading or otherwise providing content or comments). If you register for an account or create a profile through our Services, we may collect your name, login credentials and password information, phone numbers, postal address, email address, and information regarding your age, gender, or preferences (e.g., if you wish to receive newsletters).
We collect personal information about you from other sources, such as third-party consumer data vendors/resellers, data providers and aggregators, advertising networks, data analytics providers, Internet service providers, operating systems and platforms, data brokers, social networks, business contact databases, government entities, other users, and our parent companies, subsidiaries, affiliates, and other related entities.
If you choose to interact with us on social network services or use features such as plugins, widgets, or other tools provided by third-party social network services in connection with our Service, we may collect personal information made available by such services, including the personal information of your contacts on such services. For example, some social network services allow you to send content from our Service to your contacts or to extract information about your contacts to connect with them on or through our Service. Some social network services also facilitate your registration on our Service or enhance or personalize your experience on our Service.
We and our third-party business partners automatically collect personal information when you use our Services using cookies, or similar technologies. This may include information such as your IP address and the types of personal information described above as "Internet or other electronic network activity." For more information on the use of cookies and related technologies, please refer to the "Use of Cookies and Related Technologies" section.
We use the categories of personal information described above for the following business and commercial purposes:
Where required by applicable local law, our legal bases for processing your data are as follows:
Performance of a Contract: We process personal data where necessary to perform our contractual obligations to you. For example, to provide Services to you, including when you make a purchase, sign up for an event or conference, or conduct another transaction with us.
Compliance with Legal Obligations: We process personal data where necessary to comply with legal obligations to which we are subject. For example, to cooperate with public and governmental authorities, courts, or regulators as required by our legal obligations, where such processing or disclosure of personal information is necessary to protect our rights.
Legitimate Interests: We process your personal information where necessary to fulfill our legitimate business interests. For example, to ensure effective management and communication regarding our business, to conduct investigations or compliance audits, to personalize the content and information we may send or display to you, to improve the Services, to exercise or defend our rights, and for business administration purposes. When we use personal information to fulfill our legitimate interests, and where required by applicable local law, we take steps to ensure the protection of your rights. For information on how we use personal information based on this legal basis, you can contact us using the details provided in the "Contact Us" section below.
Consent: Where required by applicable law, we process personal information based on your consent. To the extent we obtain your consent for the processing of your personal data, you may have the right to withdraw your consent under applicable local law. To exercise this right, please contact us using the details in the "Contact Us" section of this Policy. If you appear in content submitted to the Services, we may ask the person submitting the content to obtain your consent.
We may disclose each of the categories of personal information described above for our business and commercial purposes as follows:
We may also disclose your personal data under the following circumstances:
We and our third-party business partners use Tracking Technologies on the Service for the purpose of Tracking Preferences. This allows for offering personalized advertising based on perceived interests inferred from the user's browsing on the Service and other sites, apps, destinations, and services, over time and across unaffiliated websites, apps, and services, using the same device or a different device. To enable tracking, we and our third-party business partners independently use Tracking Technologies.
Where required by applicable law, to opt out of tracking enabled by using your email address in coordination with audience authentication providers, visit our site at the following link: [Insert Link Here]
You may have certain rights regarding our processing of your personal data under applicable local laws, such as if you are a consumer in Italy, or a data subject in the European Union, the United Kingdom (UK), and Switzerland. If our processing of your personal data is governed by such laws, this section provides additional information about your rights and our processing of your personal data under applicable local law.
As required by applicable local law, the table below outlines our business and commercial purposes for processing your personal information, as well as the categories of third parties to whom we may disclose, "sell," or "share" for cross-contextual behavioral advertising (as such terms are defined by applicable law) the categories of personal information described above for our business and commercial purposes.
| Category of Personal Information | Our Business or Commercial Purposes for Processing | Categories of Third Parties to Whom We May Disclose Personal Information for Commercial Purposes | Categories of Third Parties to Whom We May "Sell" or "Share" Personal Information |
|---|---|---|---|
| Identifiers | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Payment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Protected Characteristics | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Commercial Information | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Payment Data | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Payment processors Order processing service providers | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Internet or Other Electronic Network Activity | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Geolocation Data | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Professional Information | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Inferences | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
| Sensitive Information | - To provide our services and fulfill your requests - To improve our services - Identification and authentication - Personalization - Marketing and promotional activities - To comply with legal obligations - To protect us and others | Data storage and security providers Order fulfillment service providers Database management providers Advertising, marketing, social media companies, subscription sales companies, and companies facilitating advertising | - Advertising, marketing, social media, and advertising facilitation companies (including list buyers and advertising clients) - Cooperatives, vendors, providers, and data aggregators - E-commerce providers - Companies that assist us with our products and product recommendations |
Your personal data will be retained only for as long as necessary for the purpose for which it was originally collected and in accordance with applicable local laws. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy. IWhen assessing retention periods, we first determine whether it is necessary to retain the personal information collected, and if retention is necessary, we strive to keep the personal information for the shortest period possible as permitted by applicable law.
Depending on the jurisdiction in which the user resides, such as if they are a consumer in Italy, or a data subject in the EU, the UK, or Switzerland, the user may have the following rights under applicable local laws:
These rights may be limited or denied in certain circumstances. For example, we may retain your personal information where required or permitted by applicable law.
To exercise your rights under applicable local law, follow the instructions provided below.
If you wish to exercise your rights under applicable law: you can contact our Data Protection Officer via email at [email protected].
We reserve the right to take reasonable steps to verify your identity before fulfilling your requests for knowledge, correction, or deletion. For example, we may try to establish your identity with a reasonable or reasonably high degree of certainty by matching the information you submit along with your request with the information we have in our records. We may ask you or your authorized agent for additional information necessary to establish your identity. Authorized agents may also be required to provide a copy of the permission signed by the consumer, authorizing the agent to submit requests on behalf of the consumer in accordance with applicable local law.
You may have the right to appeal a decision we make regarding requests to exercise your rights under applicable local law. To appeal a decision, contact our Privacy Policy Coordinator via email or as described at the end of this document.
If you no longer wish to receive marketing messages or other commercial messages from us in the future, simply follow the unsubscribe instructions contained in the message you receive. Please note, however, that you may continue to receive certain communications necessary for the Service, such as renewal notices, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.
We implement physical, technical, and organizational security measures designed to safeguard personal information. These measures are intended to protect the personal information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please note that despite our efforts, no data security measures can guarantee security.
Our Services may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this Policy but is instead governed by the privacy policies of such third-party websites and applications. We are not responsible for the information practices of such third-party websites and applications. We encourage you to review the privacy policies of any third-party website or application you choose to visit.
Please note that content and personal information you disclose in publicly accessible parts of the Service may be available to other users and may also be made available outside of the Service by third parties; therefore, you should be aware of any personal information, particularly sensitive personal information, that you may wish to post. To the extent required by applicable local law, we may require you to obtain the consent of any individual whose personal information you post on our Services.
Your personal information may be processed, transferred, and maintained on servers and databases located outside the jurisdiction in which you reside and where privacy laws may not be as protective as your jurisdiction. Where required by applicable law, we have implemented appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For further information on the appropriate safeguard measures in place, please contact us using the details provided in the “Contacts” section of this Privacy Notice.
SEALO is the data controller for your personal data. If you have any questions about the privacy aspects of our Services or if you wish to file a complaint, a request, or have a question about your rights under this policy, please contact our Data Protection Officer as follows:
Data Protection Officer Email: [email protected]
This Policy is updated as of the Last Updated date indicated above. We may modify this Policy from time to time, so be sure to check periodically. We will post any changes to this Policy on our Services. If we make changes to this Policy that materially affect our practices concerning the information we have previously collected about you, we will endeavor to provide you with prior notice of such change by highlighting the change on the Service.