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Terms and Conditions

Pre-sale Terms and Conditions:

1. The potential customer accepts without any reservation and is aware that the legal, civil, economic, and fiscal relationship arising from the purchase of this product is to be understood as "between the private buyer" and the "producing/distributing company of the product".
2. The potential customer is informed and aware that Favlino, economically, legally, fiscally, juridically, is only an external company operating in the online marketing sector, and that by virtue of its corporate purpose it may choose to handle "the conduct of advertising campaigns" for goods or services produced/distributed/commercialized by producing/distributing/commercial companies; which choose to promote their products/services through affiliate networks, to which Favlino is affiliated even temporarily. That is, Favlino chooses the products/services present in the various affiliate networks, studies the brand and implements at its own expense an online marketing strategy that exploits the various channels provided by the network (example e-commerce, Ebay, Social network etc), IN ORDER to generate useful contacts (potential customers/leads), who show interest in the products/services. And to connect such potential customers with the owning producing/distributing/commercial companies of the products/services, transferring data and any payments through appropriate contact forms provided by the affiliate network that proposes and offers without obligation to the external affiliate Favlino, to act at its own expense in the creation and conduct of advertising campaigns on its own behalf.
3. The potential customer accepts without any reservation that the data entered after clicking the buy button may be used by the company Favlino exclusively to be transferred to the producing/distributing/commercial companies through appropriate contact forms provided by the affiliate network that proposes and offers without obligation to the external affiliate Favlino, to act at its own expense in the creation and conduct of advertising campaigns on its own behalf. Beyond that, the potential customer accepts to receive future contacts from Favlino to propose new commercial offers related to this product.
4. Pre-order: the potential customer accepts without any reservation that by clicking the buy button/adding a product to the cart, they are simply making a pre-order with a subject in charge of conducting advertising campaigns, and not with a merchant or the real producer/distributor of the product. This because:
   1. Due to the nature of the product, you may be contacted by the real producer/distributor who will ensure that you can actually use the product. Only then, between you (consumer/potential customer) and the producing/distributing company a commercial transaction will be perfected and you will go from potential customer to customer and the order will be effective.
   2. Favlino is not a merchant, does not own the product, does not have physical possession of it, does not import, ship, commercialize in any way the object of this advertising listing. Only when your data is in possession and used by the producing/distributing company, between you if the prerequisites exist (your confirmation of the pre-order) a commercial transaction will be perfected and you will go from potential customer to customer of the producing/distributing company and the order will be effective.
5. Guarantees:
   1. Favlino guarantees to handle with the diligence of a good family father the data of the potential customer as well as any payments from the moment the pre-order is made until the moment of actual transfer to the producing/distributing company.
   2. Favlino although being a marketing company and not a merchant and/or the producer/distributor of the product; and has activated the advertising listing only to generate a potential non-purchasing customer, and thus a useful contact and NOT a commercial transaction, guarantees to the potential customer: assistance as much as possible in any problems arisen with the producer/distributor without being legally, juridically, fiscally and commercially obligated. Assistance that will occur with the facilitation of interactions between the potential customer and the company in requests for returns and refunds requested according to current regulations.
6. This advertising listing is addressed exclusively to private subjects and not to companies. Favlino has no financial and economic relationships with the producing/distributing companies, but only with the affiliate network that provides the offer on which to build an advertising campaign. It follows that invoicing requests from companies can be requested exclusively to the producing/distributing companies, only during the confirmation phone call, which based on their fiscal regime will choose to implement. And not to Favlino, as the same, due to the nature of the pre-order, is not certain to receive compensation for the single generated contact, but receives non-detailed compensation, exclusively from the affiliate network through which it connects potential customer and producing/distributing company.
7. Favlino does not guarantee that the products are shipped from warehouses located on Italian or San Marino territory, and that the shipment occurs through specific couriers, but only that the shipment respects the delivery times once the potential customer confirms with the producer distributor the pre-order and between the two subjects an actual commercial transaction is concluded.
8. The potential customer accepts without any reservation that Favlino is not responsible fiscally, juridically, legally and civilly for any type of dispute and/or problem of any nature arising from the confirmation of the order and the use of the product commercialized by the producing/distributing company in this listing. For any dispute refer to the producer/distributor whose company registry is always reported on the packages.
9. The potential customer accepts without any reservation that Favlino is required to refund only for purchases made with the Paypal payment system, and only in cases where the distributor/producer of the product receives the return request within the terms and in the manners provided by law, and especially only for sealed products. In the absence of a seal, no refund will be made.
10. Favlino does not guarantee the truthfulness of the information provided by the affiliate network and by the distributing/producing companies, does not guarantee compliance with current regulations by the aforementioned subjects, as it has no obligation as a marketing agency to verify anything regarding the advertised product. In this regard, the potential customer accepts without any reservation that regarding this product, the image is provided from the producer/distributor catalog, the package may differ in minor details, because the producer/distributor reserves the right to modify such details at its sole discretion. Furthermore, since producers are always committed to improving the proposed products, the potential customer also accepts that the product content may differ from the description because subjected to improvement in terms of concentration and ingredients by the producer. Of such conformity, they can get information at the time of telephone confirmation.
11. The potential customer accepts that the main payment method for this product is cash on delivery (payment upon delivery) and that it will occur only after telephone confirmation and only after receiving the product from the producer/distributor. If the potential customer chooses another payment method, Favlino may choose whether to immediately refund the customer and implement the transfer of pre-order data to the distributor/producer who will, once confirmation of purchase is received, ship the goods cash on delivery. Or without any commercial obligation arising, to collect the payment to transfer it together with the data to the distributor/producer through the contact forms provided by the affiliate network.
12. Favlino is not responsible for what any other online company, on any external or internal web page to our e-commerce, claims about the product subject of the advertising campaign.
13. In this listing NOTHING is guaranteed, NOTHING miraculous is promised, the user is NOT incited with deceptive stratagems to pre-order the product by leveraging needs and discomforts of any nature. By clicking the buy button and pre-ordering the product of this listing, the potential customer is aware of wanting to be contacted by the distributor/producer in order to purchase after telephone confirmation not by Favlino, a "product of their own free will, without any guarantee of result, without the fraudulent guarantee usually found around satisfied or refunded". FURTHERMORE Favlino ADVISES the potential customer to proceed with the pre-order ONLY if certain under medical advice to be able to come into contact with the product and that its ingredients can actually bring benefit. In addition to medical advice, it is recommended to report to the commercial/distributing/producing company by phone during the pre-order confirmation phase, every doubt and pathology or disorder.
14. The purchase of the product by minors is prohibited. The purchase by a minor can normally be declared null, because the not yet eighteen-year-old does not have the capacity to act. This gives parents the right to demand reimbursement of the amount spent, also canceling the consequences of the distance contract. This principle does not apply however in cases where the minor has concealed or falsified their age through deceptive behaviors or declaring to be of age when registering on this site.
15. Pursuant to art 52 of Legislative Decree 206/2005 and subsequent amendments and additions, except for the exceptions referred to in article 59 of the same decree, the consumer has a period of fourteen days to withdraw from a distance contract or negotiated outside commercial premises without having to provide any reason and without having to incur costs other than those provided for in article 56, paragraph 2, and article 57. Due to the nature of the pre-order, this right will start and be counted from the day the product is received at home.
16. Regarding shipping times the potential customer, by accepting the nature of the pre-order when clicking the buy button/adding the product to the cart and releasing their data, accepts without any reservation that the operating times of the distributing/producing company are as follows:
    • Pre-order forwarded up to 2:00 PM, phone call within 2 hours, from telephone confirmation 30 minutes for packaging and pickup of the item by the courier at the distributor/producer, and delivery in 1 or 2 working days.
    • Pre-order forwarded after 2:00 PM, phone call within 12 hours, from telephone confirmation 30 minutes for packaging and pickup of the item by the courier at the distributor/producer, and delivery in 1 or 2 working days.
    The potential customer therefore accepts that the times may vary due to their failure to answer the mandatory confirmation phone call from the distributor, and therefore cannot claim against Favlino in any way for possible delays.
17. Due to the mere advertising nature of the service, any negative feedback even just in the comment for product ineffectiveness, released without proof, will be reported for removal and deleted.
18. Favlino, the affiliate network, the distributing/producing companies cannot in any way be considered responsible in case of onset of pathologies and/or any type of physical condition indicated as malaise or otherwise negative for health. This because point 13 in these terms and conditions includes an information that advises the potential customer BEFORE the pre-order, to go to their attending physician and/or specialist, to know with certainty if their physical condition allows them to take or come into contact with the product in any way, without running any health risk. The potential buyer is not only informed to be made more aware of the risks deriving even from contact with the product in their specific case, but is also in several points of the description, encouraged NOT to release their data in the absence of previous medical consultation that denies its use in a certified way.
19. No term written and used on any online platform by the platform's staff, for no reason can be interpreted to change the corporate nature of Favlino. For example, if the e-commerce or other platforms identify Favlino as seller, this does not mean that it is really a company with a commercial purpose, or that it proposes advertising listings to sell and/or give rise to a direct commercial transaction between itself and a potential customer.

By making a purchase and therefore a payment, you accept every word of what is written.

COSWORLD STRATEGIC CONSTUL S.R.L – RO41633107
Suceava, Cotu Băii, Ștefan cel mare 136, 727563

Updated on 20/01/2021

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Privacy Policy

This Application collects some Personal Data from its Users.

Users may be subject to different levels of protection. Some Users therefore enjoy superior protection. Further information regarding protection criteria can be found in the applicability section.

Types of Data collected

Among the Personal Data collected by this Application, independently or through third parties, there are: name; surname; phone number; address; province; email; ZIP code; city; Cookies; Usage Data.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner. Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

Method and place of processing of collected Data

Processing methods

The Owner adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal personnel, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Owner may have access to the Data. The updated list of Processors can always be requested from the Data Controller.

Legal basis of processing

The Owner processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Owner is subject;
• processing is necessary for the execution of a task in the public interest or for the exercise of public powers vested in the Owner;
• processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.

It is always possible to ask the Owner to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Owner's operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner. The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to details on the processing of Personal Data.

In case of superior protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Owner to protect the Data.

If one of the transfers just described takes place, the User can refer to the respective sections of this document or ask for information from the Owner by contacting him at the details reported at the beginning.

Retention period

The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of such contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User's consent, the Owner may retain the Personal Data longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of the Processing of collected Data

The User's Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Commenting on content, Managing contacts and sending messages, Payment management, Remarketing and behavioral targeting, Statistics and Advertising.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data

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

Content commenting

Comment services allow Users to formulate and make public their comments regarding the content of this Application. Users, depending on the settings decided by the Owner, can leave the comment anonymously. If the Personal Data released by the User includes email, this may be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments. In the event that a comment service provided by third parties is installed, it is possible that, even if Users do not use the comment service, it collects traffic data relating to the pages where the comment service is installed.

Directly managed comment system (this Application)

This Application has its own content commenting system.

Personal Data collected: surname; email; name; phone number.

Contacting the User

Contact form (this Application)

By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header.

Personal Data collected: ZIP code; city; surname; email; address; name; phone number; province.

Mailing list or newsletter (this Application)

By registering on the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application may be sent. The User's email address may also be added to this list as a result of registering with this Application or after making a purchase.

Personal Data collected: ZIP code; city; surname; email; address; name; phone number; province.

Phone contact (this Application)

Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Application, as well as to satisfy support requests.

Personal Data collected: phone number.

Managing contacts and sending messages

This type of service allows you to manage a database of email contacts, phone contacts or contacts of any other type, used to communicate with the User. These services may also allow the collection of data relating to the date and time of viewing of messages by the User, as well as the User's interaction with them, such as information on clicks on links inserted in messages.

Skebby (Skebby – Mobile Solution S.r.l.)

Skebby is a phone contact management and communication service provided by Skebby – Mobile Solution S.r.l.

Personal Data collected: phone number.

Place of processing: Italy – Privacy Policy.

Payment management

Payment management services allow this Application to process payments by credit card, bank transfer or other instruments. The data used for payment are acquired directly by the requested payment service manager without being processed in any way by this Application. Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding payment.

PayPal (Paypal)

PayPal is a payment service provided by PayPal Inc., which allows the User to make online payments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See Paypal's privacy policy – Privacy Policy.

Advertising

This type of service allows the User's Data to be used for commercial communication purposes in different advertising forms, such as banners, also in relation to the User's interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below. Some of the services listed below may use Cookies to identify the User or use the behavioral retargeting technique, i.e. display personalized advertisements based on the User's interests and behavior, also detected outside this Application. For more information on this, we suggest checking the privacy policies of the respective services. In addition to the opt-out options offered by the services listed below, the User can opt for exclusion from receiving cookies relating to a third service, by visiting the opt-out page of the Network Advertising Initiative.

Direct Email Marketing (DEM) (this Application)

This Application uses the User's Data to send commercial proposals relating to services and products provided by third parties or unrelated to the product or service provided by this Application.

Personal Data collected: email.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User's past use of this Application. This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to which the remarketing and behavioral targeting activity is connected. In addition to the opt-out options offered by the services listed below, the User can opt for exclusion from receiving cookies relating to a third service, by visiting the opt-out page of the Network Advertising Initiative.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

Personal Data collected: Cookies; email.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Remarketing with Google Analytics (Google LLC)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Google Ads Remarketing (Google LLC)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

Users can choose not to use Google's cookies for ad personalization by visiting Google's Ads Settings.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Google Ad Manager Audience Extension (Google Inc.)

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks visitors to this Application and allows selected advertising partners to display personalized ads to them across the web.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

AdEspresso conversion tracking (Creative Web Srl)

AdEspresso conversion tracking is a statistics service provided by Creative Web Srl that connects data from the Facebook ad network with actions performed within this Application.

Personal Data collected: Cookies; Usage Data.

Place of processing: Italy – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that connects data from the Facebook ad network with actions performed within this Application. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Ads conversion tracking (Google Inc.)

Google Ads conversion tracking is a statistics service provided by Google Inc. that connects data from the Google Ads ad network with actions performed within this Application.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Twitter Ads conversion tracking (Twitter, Inc.)

Twitter Ads conversion tracking is a statistics service provided by Twitter, Inc. that connects data from the Twitter ad network with actions performed within this Application.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Yahoo Advertising conversion tracking (Yahoo! Inc.)

Yahoo Advertising conversion tracking is a statistics service provided by Yahoo! Inc. that connects data from the Yahoo ad network with actions performed within this Application.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Directly collected statistics (this Application)

This Application uses an internal statistics system, which does not involve third parties.

Personal Data collected: Cookies; Usage Data.

Further information on Personal Data

Online sale of goods and services

The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may be those relating to the credit card, the bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used.

User rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In case of superior protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out which rights are applicable in their case and how to exercise them.

In particular, the User has the right to:

• revoke consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
• oppose the processing of their Data. The User can oppose the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the correctness of their Data and request its update or correction.
• obtain the limitation of processing. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Owner will not process the Data for any other purpose than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive their Data or have it transferred to another owner. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out if the Owner processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Owner as soon as possible, in any case within one month.

Applicability of the higher level of protection

While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data.

This higher level of protection is always guaranteed when the processing:

• is performed by an Owner established in the EU; or
• concerns Personal Data of Users located in the EU and is functional to the offer of goods or services for a fee or free of charge to such Users; or
• concerns Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users to the extent that such behavior takes place within the Union.

Cookie Policy

This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.

Further information on processing

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Owner may be obliged to disclose the Data by order of public authorities.

Specific information

At the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to "Do Not Track" requests

This Application does not support "Do Not Track" requests. To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving information to Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Owner. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes concern processing whose legal basis is consent, the Owner will collect the User's consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as defined in the relative terms (if present) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Cookie

Small portion of data stored within the User's device.

Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement concerns exclusively this Application.

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Cookie Policy

This document contains information regarding the technologies that allow this Application to achieve the purposes described below. These technologies allow the Owner to collect and save information (for example through the use of Cookies) or to use resources (for example by running a script) on the User's device when the latter interacts with this Application.

For simplicity, in this document such technologies are briefly defined as "Tracking Tools", unless there is reason to differentiate. For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to talk about Cookies in the context of mobile applications, since they are Tracking Tools that require the presence of a browser. For this reason, within this document the term Cookie is used only to specifically indicate that particular type of Tracking Tool.

Some of the purposes for which Tracking Tools are used may also require the User's consent. If consent is given, it can be freely revoked at any time by following the instructions contained in this document.

This Application uses Tracking Tools managed directly by the Owner (commonly called "first party" Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly called "third party" Tracking Tools). Unless otherwise specified within this document, such third parties have access to their respective Tracking Tools. Duration and expiration of Cookies and other similar Tracking Tools may vary depending on what is set by the Owner or by each third-party provider. Some of them expire at the end of the User's browsing session.

In addition to what is specified in the description of each of the categories listed below, Users can obtain more detailed and updated information on the duration, as well as any other relevant information - such as the presence of other Tracking Tools - in the privacy policies of the respective third-party providers (through the links made available) or by contacting the Owner.

Activities strictly necessary to ensure the functioning of this Application and the provision of the Service

This Application uses Cookies commonly called "technical" or other similar Tracking Tools to carry out activities strictly necessary to ensure the functioning or provision of the Service.

Third-party Tracking Tools

Traffic optimization and distribution

This type of service allows this Application to distribute its contents through servers located throughout the territory and to optimize its performance. The Personal Data processed depends on the characteristics and implementation method of these services, which by their nature filter communications between this Application and the User's browser. Given the distributed nature of this system, it is difficult to determine the places to which the contents, which may contain the User's Personal Data, are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The Cloudflare integration methods provide that this filters all the traffic of this Application, i.e. the communications between this Application and the User's browser, also allowing the collection of statistical data on it.

Personal Data processed: Tracking Tool and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Hosting and backend infrastructure

This type of service has the function of hosting Data and files that allow this Application to function, allow its distribution and provide a ready-to-use infrastructure to provide specific features of this Application.

Some services among those listed below, if present, may work on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

Namecheap Hosting (Namecheap INC.)

Namecheap Hosting is a hosting service provided by Namecheap INC.

Personal Data processed: Usage Data; Tracking Tool; various types of Data as specified in the privacy policy of the service.

Place of processing: USA – Privacy Policy.

Other activities involving the use of Tracking Tools

Measurement

This Application uses Tracking Tools to measure traffic and analyze User behavior with the aim of improving the Service.

Heat mapping and session recording

Heat mapping services are used to identify the areas of this Application with which Users interact most frequently, in order to detect which of them attract the most interest. These services allow monitoring and analyzing traffic data and are used to keep track of User behavior. Some of these services may record sessions and make them available for later viewing.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a heat mapping and session recording service provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can tell the script not to collect any User data. This is a setting available in all major browsers. More information on opting out from Hotjar is available here.

Personal Data processed: Usage Data, Tracking Tool and various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Anonymized statistics services

The services in this section allow the Owner to process and manage statistics anonymously thanks to the use of first-party Tracking Tools.

Google Analytics with anonymized IP

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. This Google Analytics integration anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Facebook Ads conversion tracking (Facebook pixel)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Data Controller manages the processing of Data, that connects data from the Facebook ad network with actions performed within this Application. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Targeting and Advertising

This Application uses Tracking Tools to provide personalized commercial content based on User behavior and to manage, disseminate and track advertisements.

Advertising

This type of service allows the User's Data to be used for commercial communication purposes. These communications are shown on this Application in the form of banners and other forms of advertising, also in relation to the User's interests. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below. Some of the services listed below may use Tracking Tools to identify the User or use the behavioral retargeting technique, i.e. display personalized advertisements based on the User's interests and behavior, also detected outside this Application. For more information on this, we suggest checking the privacy policies of the respective services. In addition to the opt-out features offered by the services listed below, the User can opt out by visiting the opt-out page of the Network Advertising Initiative.

Users may also choose to opt out of certain advertising features through corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.

Facebook Lookalike Audience

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Data Controller manages the processing of Data, that uses the Data collected through Facebook's Custom Audience service in order to show advertisements to Users with similar behaviors to Users who are already in a Custom Audience list based on their previous use of this Application or their interaction with relevant content through Facebook's applications and services. Based on this Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Facebook Audience Network

Facebook Audience Network is an advertising service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Data Controller manages the processing of Data, For an understanding of Facebook's use of data, please consult Facebook's data policy.

To allow the operation of Facebook Audience Network, this Application may use some identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS) or technologies similar to cookies. Among the ways in which Audience Network proposes advertising messages to the User, there is also the use of the latter's advertising preferences. The User can control the sharing of their advertising preferences within the Facebook Ad settings.

The User can opt-out from some Audience Network targeting features through their device settings. For example, they can change the advertising settings available for mobile devices, or follow the instructions applicable to Audience Network that may be present within this privacy policy.

Personal Data processed: Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example) and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Remarketing and behavioral targeting

This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User's past use of this Application. This activity is facilitated by the tracking of Usage Data and the use of Tracking Tools to collect information which is then transferred to the partners who manage remarketing and behavioral targeting activities. Some services offer a remarketing option based on email address lists. In addition to the opt-out features offered by the services listed below, the User can opt out by visiting the opt-out page of the Network Advertising Initiative.

Users may also choose to opt out of certain advertising features through corresponding device configuration options, such as mobile device advertising configuration options or generic advertising configuration.

Facebook Custom Audience

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Data Controller manages the processing of Data, that connects the activity of this Application with the Facebook advertising network.

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: email and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Facebook Remarketing

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Data Controller manages the processing of Data, that connects the activity of this Application with the Facebook advertising network.

Personal Data processed: Usage Data and Tracking Tool.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

How to manage preferences and provide or withdraw consent

There are various ways to manage preferences related to Tracking Tools and to provide or withdraw consent, where necessary:

Users can manage preferences related to Tracking Tools directly through their device settings - for example, they can prevent the use or storage of Tracking Tools.

In addition, whenever the use of Tracking Tools depends on consent, the User can provide or withdraw such consent by setting their preferences within the cookie policy or updating such preferences through the tracking settings widget, if present.

Thanks to specific browser or device functions, it is also possible to remove previously saved Tracking Tools.

Other Tracking Tools present in the browser's local memory can be removed by deleting the browsing history.

As regards third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the relevant opt out link (if available), using the tools described in the third party's privacy policy or contacting it directly.

Locate the settings related to Tracking Tools

Users can, for example, find information on how to manage Cookies in some of the most popular browsers at the following addresses:

• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Internet Explorer
• Microsoft Edge
• Brave
• Opera

Users can also manage some Tracking Tools for mobile applications by deactivating them through the appropriate device settings, such as the advertising settings for mobile devices or settings related to tracking in general (Users can consult the device settings to identify the relevant one).

Advertising industry initiatives for consent management

Notwithstanding the foregoing, Users are informed of the possibility of using the information on YourOnlineChoices (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services it is possible to manage the tracking preferences of most advertising tools. The Owner, therefore, advises Users to use these resources in addition to the information provided in this document.

The Digital Advertising Alliance also provides an application called AppChoices that helps Users control behavioral advertising on mobile applications.

Data Controller

Owner's email address: office@shoptopon.com

Since the use of third-party Tracking Tools on this Application cannot be completely controlled by the Owner, any specific reference to third-party Tracking Tools is to be considered indicative. To obtain complete information, Users are kindly invited to consult the privacy policy of the respective third-party services listed in this document.

Given the objective complexity of identifying tracking technologies, Users are invited to contact the Owner if they wish to receive further information regarding the use of such technologies on this Application.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the User's IT environment.

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