Privacy policy

The purpose of this document (hereinafter “Privacy Policy”) is to inform Users about personal data, understood as any information that allows the identification of a natural person (hereinafter the “Personal Data”), collected by the website www.freedompro.eu (hereinafter “Application“).

The Data Controller, as subsequently identified, may modify or simply update, in whole or in part, this Information by informing Users. Changes and updates will be binding as soon as they are published on the Application. The User is therefore invited to read the Privacy Policy each time they access the Application.

In the event of non-acceptance of the changes made to the Privacy Policy, the User is required to cease using this Application and may request the Data Controller to remove their Personal Data.

1. Personal Data collected by the Application
   The Data Controller collects the following types of Personal Data:
   
   
   • A. Contents and information provided voluntarily by the User
     
     
     • Contact data and contents: are those Personal Data that the User voluntarily provides to the Application during its use, such as for example personal data, contact details, access credentials for the services and/or products provided, personal interests and preferences and other personal content, etc.
     
     
     • Sensitive data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, Data relating to a natural person's health or sexual life or sexual orientation.
     
     
     • Personal data collected by social media:  Users can share data provided to social media with the Application. The User has the right to control the Personal Data that the Application can access through the privacy settings available on the social media in question. By associating accounts managed by social media with the Application and authorizing the Owner to access such Personal Data, the User gives consent to the acquisition, processing and storage thereof in accordance with this Privacy Policy.
     
     Failure by the User to provide Personal Data, for which there is a legal or contractual obligation or if they constitute a necessary requirement for the use of the service or for the conclusion of the contract, will make it impossible for the Owner to provide all or part of its services.
     
     The User who communicates the Personal Data of third parties to the Owner is directly and exclusively responsible for their origin, collection, processing, communication or dissemination.
     
     
   • B. Data and content acquired automatically during use of the Application
     
     
     • Technical data: the computer systems and software procedures used to operate this Application may acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified Users, but which by its very nature could, through processing and association with Data held by third parties, allow Users to be identified. This category includes IP addresses, or domain names used by Users who connect to the Application, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained, etc.
     
     
     • Usage data: Personal Data relating to the use of the Application by the User may also be collected, such as the pages visited, the actions performed, the functions and services used.
     
     
   • C. Personal data collected through cookies or similar technologies
     
     
     • The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect Personal Data on the pages, links visited and other actions performed when using our services. They are stored before being retransmitted on the next visit by the same User.
     
     The User can view the complete Cookie Policy below.
     
     
2. Purpose
   I Personal Data is communicated to  Shopify Inc, Google Inc, ZMeta Platforms Inc, LinkedIn Inc, Twitter Inc, Apple Inc, Paypal Holdings, Intercom Inc, bindCommerce Srl, UPS United Parcel Service of America, Inc.
   
   I Personal data collected may be used for the execution of contractual and pre-contractual obligations and for legal obligations as well as for the following purposes:
   
   
   • Registration and authentication of the User: to allow the User to register on the Application to access and be identified.Z
     
   • Support and contact with the User: to respond to User requests and help in case of problems.Z
     
   • Comment and Feedback: to allow the User to send reviews or comments.Z
     
   • Communication via live Chat:   to allow the User to interact with a live chat on the Application.
     
   • Displaying content from external platforms: to allow the User to view and share content from social networks or other external platforms.Z
     
   • Login through accounts on external platforms: to allow the User to log in to the Application through an account on external platforms (e.g. Google, Facebook).Z
     
   • External management of payments via credit card, bank transfer or other instruments: to manage User payments via external platforms that acquire payment data without the Application owner having access.
     
   • Internal management of payments via credit card, bank transfer or other instruments: to manage payments by acquiring payment data directly from the User.
     
   • Archiving, hosting and backend infrastructure management: to manage the technical infrastructure for archiving User data.
     
   • Technical monitoring of the infrastructure for maintenance, troubleshooting and performance improvement: to identify and resolve any technical problems and improve performance.Z
     
   • Traffic optimization and distribution: to more efficiently manage and improve the performance of the technical infrastructure.
     
   • Management of User databases: to organize, access and modify User data. Personal Data is communicated to third-party service providers for data storage.
     
   • Statistics only with anonymous data: to carry out statistical analyzes based on aggregate data or data that do not allow the User to be identified.
     
   • Monitoring, analysis and tracking of User behavior: to monitor and analyze how the User behaves on the Application.
     
   • User profiling: to automatically group and analyze the characteristics or behaviors of the User and provide them with personalized services or messages.
     
   • Sending emails or newsletters and managing mailing lists: to contact the User with emails containing commercial and promotional information relating to the Application.
     
   • Electronic invoicing: To generate electronic invoices, communicate to the Exchange System and store the invoices.
     
   • Targeting advertising and remarketing: to show more relevant advertisements to the User based on their browsing behavior and preferences.
     
     
3. Method of processing
   The processing of Personal Data is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.
   
   In some cases, subjects involved in the Data Controller's organization (such as example, personnel management workers, commercial area workers, system administrators, etc.) or external parties (such as IT companies, service providers, postal couriers, hosting providers, etc.). If necessary, these subjects may be appointed as Data Processors by the Owner, as well as access the Users' Personal Data whenever necessary and will be contractually obliged to keep the Personal Data confidential.
   
   The updated list of Data Processors can be requested via email at the address privacy@freedompro.eu.
   
   
4. Legal basis of processing
   The processing of Personal Data relating to the User is based on the following legal bases:Z
   
   
   • the consent given by the User for one or more specific purposes;
     
     
   • processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
     
     
   • processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
     
     
   • processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
     
     
   • processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties;
     
     
   • processing is necessary for the pursuit of a vital interest of the Data Controller or of third parties.
     
     It is however always possible to request the Data Controller to clarify the legal basis of each processing at the address privacy@freedompro.eu.
     
     
     
5. Place
   I Personal Data is processed at the Data Controller's operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller at the following email address privacy@freedompro.eu or at the following postal address of the operational headquarters Vicinale delle Roveri snc, Bovisio Masciago 20813 Italy.
   
   I Personal Data may be transferred to non-EU countries: USA, Canada.
   
   For these countries there is a decision of adequacy of the European Commission or, in the absence of such a decision, it is possible to request more information from the Owner regarding the appropriate guarantees adopted, as well as the means to obtain a copy of such Data or the exact place where they were made available.
   
   
6. Security measures
   The Processing is carried out according to methods and with tools suitable to guarantee the security and confidentiality of the Personal Data, the Data Controller having adopted adequate technical and organizational measures which guarantee, and allow to demonstrate, that the Processing is carried out in compliance with the legislation reference.
   
   
7. Data retention period
   I Personal Data will be retained for the period of time necessary to fulfill the purposes for which they were collected.
   
   In particular, the Personal Data will be retained for the entire duration of the contractual relationship, for the execution of the obligations inherent thereto and consequent, for compliance with applicable legal and regulatory obligations, as well as for own or third party defensive purposes.
   
   If the processing of Personal Data is based on the User's consent, the Data Controller may retain the Personal Data until the consent is revoked.
   
   I Personal Data may be retained for a longer period if necessary to fulfill a legal obligation or by ordine of an authority.
   
   All Personal Data will be deleted or stored in a form that does not allow identification of the User within 30 days of the end of the retention period. Upon expiration of this period, the right of access, cancellation, rectification and the right to portability of Personal Data can no longer be exercised.
   
   
8. Automated decision-making processes
   The Application uses automated decision-making processes that can produce legal effects for the person or significantly impact them and which operate according to these criteria: We have created an automated flow for partner management, these are the steps: – reception of data deriving from a web form – data evaluation (manual and/or automatic) – sending feedback - sending contract to be signed electronically in case of acceptance - automatic creation of the profile on our store - sending communications dedicated to commercial proposals - follow up after purchase In general we have created different automated flows for managing contacts based on the characteristics of each one.
   
   
9. User rights
   Users can exercise certain rights with reference to the Personal Data processed by the Owner. In particular, the User has the right to:
   
   • revoke consent at any time;
   • Object to the processing of your Personal Data;
   • access your Personal Data;
   • check and request rectification;
   • obtain the limitation of processing;
   • obtain the deletion of your Personal Data;
   • receive your Personal Data or have it transferred to another owner;
   • lodge a complaint with the Personal Data Protection Supervisory Authority and/or take legal action.
     
     To exercise their rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are made free of charge and processed by the Data Controller as quickly as possible, in any case within 30 days.
     
     
10. Data Controller
    The Data Controller is Freedompro S.r.l., with operational headquarters in Vicinale delle Roveri snc 20813 Bovisio Masciago, Tax Code / VAT number 08191460966, address email info@freedompro.eu.