Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, username, email address, various types of Data, Usage Data, website, first name and last name.

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.
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The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.The Data processing is carried out using computers and/or IT enabled tools, following organizational 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.
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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.
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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 organization 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 inquire with the Owner using the information provided in the contact section.
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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 to 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 Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Traffic optimization and distribution, Hosting and backend infrastructure, Registration and authentication, Analytics, Displaying content from external platforms, User database management, Managing contacts and sending messages, Contacting the User, Managing support and contact requests, Content commenting, SPAM protection and Remarketing and behavioral targeting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
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Personal Data is collected for the following purposes and using the following services:

Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)Google Analytics is a web analysis service provided by Google Inc. (“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.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.

Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
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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 collected: email address.

Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.

Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
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Comment system managed directly (this Application)
This Application has its own internal content comment system.
Personal Data collected: email address, username and website.

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.

Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
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Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

SoundCloud widget (SoundCloud Limited)
Soundcloud is an audio content delivery service provided by SoundCloud Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data.
Place of processing: Germany – Privacy Policy.

Spotify widget (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: Sweden – Privacy Policy.
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Typekit (Adobe Systems Incorporated)
Typekit is a typeface visualization service provided by Adobe Systems Incorporated that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
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Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

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.

MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
Place of processing: US – Privacy Policy.

Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.Personal Data collected: email address, username and various types of Data.

Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
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SPAM protection
This type of service analyzes 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 recognized as SPAM.

Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize 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 User are transferred.

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.

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.
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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.
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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.

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.

Palmesino Rönnskog Territorial Agency Limited
7 Swinton Street
London WC1X 9NL
United Kingdom
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Owner contact: Contact
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This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
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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.
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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.
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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) 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 honor the “Do Not Track” requests, please read their privacy policies.
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The Owner reserves the right to make changes to this privacy policy at any time by giving notice to 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.

If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
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Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, 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 server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

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

Data SubjectThe natural person to whom the Personal Data refers.
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Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User’s device.

This Application uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of this Application, for example in relation to the distribution of traffic.
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This Application uses Cookies to save browsing preferences and to optimize the User’s browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.
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Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.
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If any third party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

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

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“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.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.

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.

Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Twitter feed widget (Twitter, Inc)Twitter is a short message content visualization service provided by Twitter, Inc that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize 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 User are transferred.

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.
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In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies.
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Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website.
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.
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With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party’s privacy policy, or by contacting the third party.

Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

Since the installation of third-party Cookies and other tracking systems through the services used within this Application cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.
Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by this Application.
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Palmesino Rönnskog Territorial Agency Limited
7 Swinton Street
London WC1X 9NL
United Kingdom

Owner contact: Contact
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Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
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Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, 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 server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
UserThe individual using this Application who, unless otherwise specified, coincides with the

Data Subject.
Data SubjectThe natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This ApplicationThe means by which the Personal Data of the User is collected and processed.

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

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User’s device.

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
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This privacy policy relates solely to this Application, if not stated otherwise within this document.

Last update: 2 June 2018