Privacy Policy

Privacy Policy

Effective date: June 4th, 2018

RM PROMOTION SAGL, Lugano (“us”, “we”, or “our”) operates the https://www.raffaelemarciello.com/ website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Definitions

Service
Service is the https://www.raffaelemarciello.com/ website operated by RM PROMOTION SAG, Lugano.

Personal Data
Personal Data means data about a natural person who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any natural person who is using our Service and is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you. In particular, we collect such data, in order to understand where our users come from for strategic and marketing purposes.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Canton/Region/Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

 

Use of Data

RM PROMOTION SAGL uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

 

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), RM PROMOTION SAGL legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

RM PROMOTION SAGL may process your Personal Data because:

  • you have given us permission to do so, or
  • the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or
  • the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, or
  • to comply with the law.

 

Retention of Data

RM PROMOTION SAGL will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

RM PROMOTION SAGL will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

 

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, canton/region/province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Switzerland and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

RM PROMOTION SAGL will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances, RM PROMOTION SAGL may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

RM PROMOTION SAGL may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of RM PROMOTION SAGL
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability.

Security Of Data

The security of your data is important to us. Please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we will strive to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, but we cannot guarantee its absolute security.

 

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. RM PROMOTION SAGL aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you;

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

The right to object. You have the right to object to our processing of your Personal Data;

The right of restriction. You have the right to request that we restrict the processing of your personal information;

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format;

The right to withdraw consent. You also have the right to withdraw your consent at any time where RM PROMOTION SAGL relied on your consent to process your personal information;

The right not to be subject to a decision based solely on automated processing, including profiling;

The right to get communication of a personal data breach.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We use the following service providers:

Google Analytics

Google Analytics is a digital analytics tool provided by Google Inc., that tracks and reports website traffic, in particular by using tracking codes which record, collect  and transmit visitor data to a Google server and set a cookie on each visitor’s computer.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://www.google.com/intl/en/policies/privacy/.

WordPress

WordPress uses cookies, or tiny pieces of information stored on your computer, to verify who you are. There are cookies for logged in users and for commenters. In particular, WordPress verifies if the browser accepts the cookie and if the administrator got access to the website (wp-settings-time-1).

For more information on the privacy and cookies practice of WordPress, please visit the WordPress Privacy Terms web page: https://wordpress.org/about/privacy/  and the WordPress Cookie Policy: https://wordpress.org/about/privacy/cookies/.

 

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us: