Calaber collects certain Personal Data from its Users.

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POLICY SUMMARY

PERSONAL DATA PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES.

• CONTENT COMMENTARY
• DIRECTLY MANAGED COMMENT SYSTEM

Personal Data: surname; Usage data; email; name; username

• CONTACTING YOU
• CONTACT FORM

Personal Data: surname; email; name; various types of Data

• CONTACT BY PHONE

Personal Data: telephone number

• HOSTING AND BACKEND INFRASTRUCTURE
• SERVERPLAN

Personal Data: Usage Data

• INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS
• FACEBOOK LIKE BUTTON AND SOCIAL WIDGETS AND TWEET BUTTON AND TWITTER SOCIAL WIDGETS

Personal Data: Usage Data; Tracking Tools

• SPAM PROTECTION
• GOOGLE RECAPTCHA

Personal Data: clicks; Usage data; keypress events; events related to motion sensors; touch events; mouse movements; position relative to scrolling; answers to questions; Tracking Tools

• STATISTICS
• GOOGLE ANALYTICS

Personal Data: Usage Data; Tracking Tools

• DISPLAYING CONTENT FROM EXTERNAL PLATFORMS
• GOOGLE FONTS AND AWESOME FONTS

Personal Data: Usage Data; Tracking Tools

• WIDGET GOOGLE MAPS

Personal Data: Usage Data

CONTACT INFORMATION

·

• DATA CONTROLLER

Calaber

Merwalveeg 106

1121 LD Landsmeer ( Netherlands)

Owner contact email: [email protected]

COMPREHENSIVE POLICY

TYPES OF DATA COLLECTED

Among the types of Personal Data that Calaber collects, by itself or through third parties, there are: Tracking Tools; Usage data; name; surname; email; various types of Data; username; phone number; answers to questions; click; keypress events; events related to motion sensors; mouse movements; position relative to scrolling; touch events.

Full 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 is collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using Calaber. Unless otherwise specified, all Data requested by Calaber are mandatory. If the User refuses to communicate them, it may be impossible for Calaber to provide the Service. In cases where Calaber 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 on 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 Calaber or by the owners of third-party services used by Calaber, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional 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 Calaber and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

METHOD AND PLACE OF PROCESSING OF COLLECTED DATA

PROCESSING METHODS

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Data Personali.Il processing is carried out using IT and / or telematic tools, with organizational methods and with logic 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 Calaber (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 Data Processors can always be requested from the Data Controller.

LEGAL BASIS OF THE PROCESSING

The Data Controller 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 Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("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;

· the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;

· the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

· the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

· the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

PLACE

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the Data Controller.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 the details on the processing of Personal Data.

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 of public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.The User can check if one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.

RETENTION PERIOD

The Data are processed and stored for the time required by the purposes for which they were 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 this contract is completed.

· Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. 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 Data Controller.

When the processing is based on the User's consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep 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, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

PURPOSE OF THE PROCESSING OF COLLECTED DATA

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Displaying content from external platforms, Contacting the User, Interaction with external social networks and platforms, Content commenting, SPAM protection and Hosting and backend infrastructure.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.

DETAILS ON THE PROCESSING OF PERSONAL DATA

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

· CONTENT COMMENTARY

The comment services allow Users to formulate and make public their comments regarding the content of Calaber . Users, depending on the settings decided by the Owner, can also leave the comment anonymously. If among the Personal Data released by the User there is an email, this could 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 (Calaber)

Calaber has its own content commenting system.

Personal Data processed: surname; Usage data; email; name; username.

· CONTACTING YOU

CONTACT FORM (Calaber)

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 processed: surname; email; name; various types of Data.

CONTACT BY PHONE (Calaber)

Users who have provided their telephone number may be contacted for commercial or promotional purposes related to Calaber, as well as to fulfill support requests.

Personal Data processed: telephone number.

· HOSTING AND BACKEND INFRASTRUCTURE

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

Some of the services listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

Aruba is a hosting and backend service provided by Aruba.

Personal Data processed: Usage data.

Place of processing: Italy –

· INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS

This type of service allows interaction with social networks, or other external platforms, directly from the pages of Calaber. The interactions and information acquired by Calaber are in any case subject to the User's privacy settings related to each social network. This type of service could still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out of the respective services to ensure that the data processed on Calaber is not linked back to the User's profile.

· SPAM PROTECTION

This type of service analyzes Calaber traffic, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.

GOOGLE RECAPTCHA (GOOGLE IRELAND LIMITED)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.The use of the reCAPTCHA system is subject to google.

Personal Data processed: clicks; Usage data; keypress events; events related to motion sensors; touch events; mouse movements; position relative to scrolling; answers to questions; Tracking Tools.

Place of processing: Ireland –

· 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 IRELAND LIMITED)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of Calaber, 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; Tracking Tools.

· DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of Calaber and interact with them. This type of service could still collect data on web traffic related to the pages where the service is installed, even when users do not use it.

GOOGLE FONTS (GOOGLE IRELAND LIMITED)

Google Fonts is a font style display service managed by Google Ireland Limited that allows Calaber to integrate such content into its pages.

Personal Data processed: Usage data; Tracking Tools.

WIDGET GOOGLE MAPS (GOOGLE IRELAND LIMITED)

Google Maps is a map visualization service managed by Google Ireland Limited that allows Calaber to integrate such content within its pages.

Personal Data processed: Usage data.

FONT AWESOME (FONTICONS, INC.)

Font Awesome is a font style display service managed by Fonticons, Inc. that allows Calaber to integrate such content into its pages.

Personal Data processed: Usage data; Tracking Tools.

Place of processing: United States –

USER RIGHTS

Users may exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

· withdraw consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.

· oppose the processing of their data. The User may object to the processing of their Data when it takes place on a legal basis other than consent. Further details on the right to object can be found in the section below.

· access your Data. The User has the right to obtain information on the Data processed by the Data Controller, 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 updating or correction.

· obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller 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 may request the cancellation of their Data by the Owner.

· receive their Data or have them transferred to another holder. The User has the right to receive their Data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data are 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 may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

DETAILS ON THE RIGHT TO OBJECT

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

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

HOW TO EXERCISE YOUR RIGHTS

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

COOKIE POLICY

Calaber uses Tracking Tools.

FURTHER INFORMATION ON THE TREATMENT

DEFENCE IN COURT

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of Calaber 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 the public authorities.

SPECIFIC INFORMATION

At the request of the User, in addition to the information contained in this privacy policy, Calaber 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 operation and maintenance purposes, Calaber and any third-party services used by Calaber may collect files that record interaction with Calaber (System logs) use other Personal Data (such as the IP Address) for this purpose.

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

Calaber does not support "Do Not Track" requests. To find out if any third-party services used support them, the User is invited to consult the 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 notifying Users on this page and, if possible, on Calaber and, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Please therefore consult this page frequently, referring to the date of last modification indicated at the bottom. If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

DEFINITIONS AND LEGAL REFERENCES

PERSONAL DATA (OR DATA)

Personal data is 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.

USAGE DATA

Information collected automatically through Calaber (or third-party services employed in Calaber), which can include: the IP addresses or domain names of the computers utilized by the Users who use Calaber, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received 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 the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, parameters relating to the operating system and the User's IT environment.

USER

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

INTERESTED

The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR MANAGER)

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

DATA CONTROLLER (OR DATA CONTROLLER)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Calaber. The Data Controller, unless otherwise specified, is the Owner ofCalaber.

Calaber

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

SERVICE

The Service provided by Calaber as described in the relative terms (if available) and on this site/application.

EUROPEAN UNION (OR EU)

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

COOKIE

Cookies are Tracking Tools that consist of small portions of data stored within the User's browser.

TRACKING TOOL

Tracking Tool means any technology - eg. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allows tracking of Users, for example by collecting or saving information on the User's device.

LEGAL REFERENCES

This privacy statement has been prepared on the basis of multiple legislative systems, including Articles. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement applies exclusively to Calaber. .