Owner and Data Controller

Wenda srl, Via S. Quasimodo 42 40013 Castel Maggiore (BO)

Owner contact email: info@wenda-it.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; Trackers; Usage Data; first name; last name; number of Users; device information; session statistics; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; various types of Data; username; geographic position; state; Data communicated while using the service; website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

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

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Retention time

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

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

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: Contacting the User, Analytics, User database management, Managing contacts and sending messages, Interaction with external social networks and platforms, Advertising, Tag Management, Remarketing and behavioural targeting, Displaying content from external platforms, Traffic optimisation and distribution, SPAM protection, Heat mapping and session recording, Interaction with online survey platforms, Interaction with data collection platforms and other third parties and Managing data collection and online surveys.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

• Advertising

  This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  Google Ad Manager (Google Ireland Limited)

  Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  In order to understand Google's use of Data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behaviour concerning ads, products and services offered.  

   

  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Google Ads Similar audiences (Google Ireland Limited)

  Similar audiences is an advertising and behavioural targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behaviour to Users who are already on the remarketing list due to their past use of this Application.
  On the basis of this Data, personalised ads will be shown to Users suggested by Google Ads Similar audiences.

   

  Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.

   

  In order to understand Google's use of Data, consult Google's partner policy.

  Personal Data processed: Trackers; Usage Data.

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

• Analytics

  The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

  HubSpot Analytics (HubSpot, Inc.)

  HubSpot Analytics is an analytics service provided by HubSpot, Inc.

  Personal Data processed: Trackers; Usage Data.

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

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

  Personal Data processed: Trackers; Usage Data.

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

  Google Analytics 4 (Google Ireland Limited)

  Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

  Personal Data processed: device information; number of Users; session statistics; Trackers; Usage Data.

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

  Google Analytics Demographics and Interests reports (Google Ireland Limited)

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).

   

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

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

  Matomo (this Application)

  Matomo is an analytics software used by this Application to analyse data directly without the help of third parties.

  Personal Data processed: Trackers; Usage Data.

  LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

  LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Application.

   

  Users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.

  Personal Data processed: device information; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Google Analytics Advertising Reporting Features (Google Ireland Limited)

  Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

   

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

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

  Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

  Hotjar is an analytics service provided by Hotjar Ltd.
  Hotjar honours generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

  Personal Data processed: Trackers; Usage Data.

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

• Contacting the User

  Mailing list or newsletter (this Application)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

  Personal Data processed: email address.

• Displaying content from external platforms

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

  YouTube video widget (Google Ireland Limited)

  YouTube is a video content visualisation service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  YouTube video widget (Privacy Enhanced Mode) (Google Ireland Limited)

  YouTube is a video content visualisation service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
  This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on this Application unless they play the video.

  Personal Data processed: Trackers; Universally unique identifier (UUID); Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Heat mapping and session recording

  Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
  Some of these services may record sessions and make them available for later visual playback.

  Hotjar Heat Maps & Recordings (Hotjar Ltd.)

  Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
  Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

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

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

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  Hotjar Recruit User Testers (Hotjar Ltd.)

  The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd.
  Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

  Personal Data processed: Trackers; Usage Data; various types of Data.

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

• 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 this Application.
  The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
  This type of service might 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 from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

• Interaction with online survey platforms

  This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  Hotjar Poll & Survey widgets (Hotjar Ltd.)

  The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
  Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

  Personal Data processed: Trackers; Usage Data; various types of Data.

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

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  HubSpot Email (HubSpot, Inc.)

  HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

  Personal Data processed: email address; Usage Data.

  Place of processing: United States – Privacy Policy.

• Managing data collection and online surveys

  This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

  Hotjar surveys (Hotjar Ltd.)

  Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
  Hotjar surveys may use cookies to track User behaviour. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.

   

  Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.

  Personal Data processed: Data communicated while using the service; email address; first name; geographic position; last name; state; Trackers; Usage Data; username; website.

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

• Remarketing and behavioural targeting

  This type of service allows this Application and its partners to inform, optimise and serve advertising based on past use of this Application by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
  Some services offer a remarketing option based on email address lists.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  Google Ads Remarketing (Google Ireland Limited)

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

   

  In order to understand Google's use of Data, consult Google's partner policy.

   

  Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.

  Personal Data processed: Trackers; Usage Data.

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

  Remarketing with Google Analytics (Google Ireland Limited)

  Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.

  Personal Data processed: Trackers; Usage Data.

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

  LinkedIn Website Retargeting (LinkedIn Corporation)

  LinkedIn Website Retargeting is a remarketing and behavioural targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.

  Personal Data processed: Trackers; Usage Data.

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

• SPAM protection

  This type of service analyses the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralised fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Traffic optimisation and distribution

  This type of service allows this Application to distribute their content using servers located across different countries and to optimise their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare Inc.)

  Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.

  Personal Data processed: Trackers.

  Place of processing: United States – Privacy Policy.

• User database management

  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

  HubSpot CRM (HubSpot, Inc.)

  HubSpot CRM is a User database management service provided by HubSpot, Inc.

  Personal Data processed: email address; first name; last name.

  Place of processing: United States – Privacy Policy.

  HubSpot Lead Management (HubSpot, Inc.)

  HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

  Personal Data processed: email address; first name; last name.

  Place of processing: United States – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

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

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

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

System logs and maintenance

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

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.