Privacy Policy

​

 

This project collects some Personal Data from its Users.

​

Data Controller: R & R Media Compass Rose BV, Lijmbeekstraat 188, 5612NJ Eindhoven, The Netherlands

​R&R Media Compass Rose B.V is a Dutch company that, through other websites belonging to it, deals with the collection and management of user data concerning the services offered. R&R Media Compass Rose B.V (LEAN ADV) registered in Lijmbeekstraat 188, 5612 NJ, EINDHOVEN, The Netherlands - VAT: NL856133358B01 - KVK: 65490266.

​

1. Types of Data collected

Among the Personal Information collected by this Application, either independently or through third parties, there are name, surname, company name, title, social security number, address, email address, city, postcode, IP address, opt-in date, country optin, cookies and usage data.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to communicate with them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation. Users who have doubts about which data are mandatory are encouraged to contact the owner. Any use of Cookies - or other tracking tools - by this Application or third-party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and the Cookie Policy, if available.

The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

​​

​

​

2. Method and place of processing of the collected data

​​

​

2.1 Processing methods

​

The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers, may have access to Data) hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller.

​​

​

2.2 Legal basis for processing

​

The Holder processes Personal Data relating to the User in the event one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation regarding the protection of Personal Data;

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

• the processing is necessary to fulfil a legal obligation to which the Data Controller is subject;

• the processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Holder;

• the processing is necessary for the pursuit of the legitimate interest of the owner or third parties.

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

​​

​

2.3 Place

​

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the owner. The User's Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the processing site, the User can refer to the section concerning the processing of Personal Data.

You have the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data. Should one of the transfers described above take place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening dates.

​

​

2.4 Storage period

​

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of the contract is completed.

• Personal Data collected for purposes related to the Data Controller's legitimate interest will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or an order of an authority. At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

​

​​

​

3. Purposes of the processing of collected data

​

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Billing communications, Tracking platform, Registration and authentication, Statistics and Displaying content from external platforms.

To obtain further detailed information on the purposes of the processing and the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data

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

​​

​

3.1 Contacting the User Contact 

The User, by filling out the contact form with his own Data, consents to their use to respond to requests for information, quotation, or any other kind indicated by the form header. 
Personal Data collected: email, first name.

​​

​

3.2 Managing contacts and sending messages 

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. 
These services may also allow us to collect data relating to the date and time the messages are displayed by the User, as well as to the User's interaction with them, such as information on clicks on the links inserted in the messages. 
Sendgrid 
Sendgrid is a service for managing addresses and sending e-mails. 
Personal Data collected: surname, Usage data, email address, first name, phone number, company name and username.

​​

​

3.3 Tracking platform 

This type of service has the function of hosting data and files that allow this application to work, allow distribution and make available a ready-to-use infrastructure to provide the specific features of this application. Some of these services work through geographically dispersed servers in different locations, making it difficult to determine the exact location where Personal Data is stored. 
Afftrack is the tracking platform that uses this application to allow customers and affiliates to track commissions generated.
Personal Data collected: name, surname, company name, title, social security number, address, email address, city, postcode, ip address, optin date, optin country.

​​

​

3.4 Registration and authentication 

By registering or authenticating the User allows the Application to identify it and give it access to dedicated services. Depending on the following, the registration and authentication services may be provided with the help of third parties. If this happens, this application will be able to access some data stored by the third-party service used for registration or identification. Registration takes place directly via our tracking platform. 
Afftrack is the tracking platform that uses this application to allow customers and affiliates to keep track of the commissions generated
Personal Data collected: Cookies, various types of Data as specified in the privacy policy of the service, name, surname, company name, title, social security number, address, email address, city, postal code, ip address, optin date, country of 'optin.
 

​

3.5 Statistics 

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour. Google Analytics (Google Inc.) Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected for tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualise and personalize the advertisements of its advertising network. 
Personal Data collected: Cookies and Usage Data.
 

​

3.6 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. If a service of this type is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed. 
Google Fonts (Google Inc.) Google Fonts is a service of visualization of font styles managed by Google Inc. that allows this application to integrate such contents within its pages. 
Personal Data collected: Usage Data and various types of Data as specified in the service's privacy policy.

Gravatar (Automattic Inc.) Gravatar is an image visualization service managed by Automattic Inc. that allows this application to integrate such contents within its pages. Please note that if the Gravatar images are used for comment systems, the commentator's email address (or parts of it) may be sent to Gravatar, even if it is not subscribed to this service. 
Personal Data collected: Usage data and email address. 

Google Maps Widget (Google Inc.) Google Maps is a map visualization service managed by Google Inc. that allows this application to integrate such contents within its pages. 
Personal Data collected: Cookies and Usage Data.

YouTube Video Widget (Google Inc.) YouTube is a video content visualization service managed by Google Inc. that allows this application to integrate such content within its pages. 
Personal Data collected: Cookies and Usage Data. *

 

 

Commercial, marketing and advertising communication purposes. Subject to the User's consent, the Controller may process Personal Data for commercial, marketing and advertising communication purposes to inform about promotional initiatives related to Products, services, events and initiatives promoted by Lean ADV. These activities will be carried out through automated methods of contact (email, sms, notifications in App, WhatsApp, etc.). The processing of Personal Data for this purpose finds its legal basis in art. 6 par. 1 lett.) of the GDPR and is therefore based on consent. The User may revoke the consent given and/or object, at any time, to the processing of his or her data for marketing purposes. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to withdrawal.

​

​

4. Further information on Personal Data

​

4.1 The Service is not intended for children under 13 years 
Users state that they are of legal age according to the legislation applicable to them. 
Minors may use this Application only with the assistance of a parent or guardian. Under no circumstances under 13 can use this Application.

​

​

5. Rights of the User

​

Users may exercise certain rights regarding the Data processed by the Data Controller.

In particular, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.

• oppose the processing of your data. You may object to the processing of your data when it occurs on a legal basis other than consent. Further details on the right of opposition are indicated in the section below.

• access your data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

• verify and request rectification. The User can verify the correctness of his Data and request its updating or correction.

• obtain treatment limitation. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.

• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.

• receive your data or have it transferred to another holder. You have the right to receive your data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.

• propose a complaint. The User can complain about the competent personal data protection authority or act in court.

​​​

​

5.1 Details on the right of opposition

​

When Personal Data is processed in the public interest, in the exercise of public authority to which the Holder is invested or to pursue a legitimate interest of the Owner, Users have the right to oppose the processing for reasons related to their particular situation.

Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Owner deals with data for direct marketing purposes, Users can refer to the respective sections of this document.

​​

​

5.2 How to exercise the rights

​

To exercise the rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. The requests are deposited free of charge and processed by the Owner as soon as possible, in any case within a month.

​

​​

​

6. Cookie Policy

​

This application uses cookies. To learn more and to read the detailed information, the User can consult the Cookie Policy.

​​

​

​

7. Further information on treatment

​​

​

7.1 Defense in court

​

The User's Personal Data may be used by the Owner in court or the preparatory stages of its possible establishment for the defence against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Data Controller may be obliged to disclose the public authorities' data.

​

​

7.2 Specific information

​

At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

​​

​

7.3 System logs and maintenance

​

For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, ie files that record the interactions and that may also contain Personal Data, such as the User IP address.

​

​

7.4 Information not contained in this policy

​

Further information concerning the processing of Personal Data may be requested at any time to the Data Controller using the contact details.

​

​

7.5 Response to "Do Not Track" requests

​

This Application does not support "Do Not Track" requests. To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.​

​

​

7.6 Changes to this privacy policy

​

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the extremes contact information in the owner's possession. Please, therefore, consult this page regularly, referring to the date of the last modification indicated at the bottom. If the modifications concern treatments whose legal basis is consent, the Controller will collect the User's consent again, if necessary.

Definitions and legal references

​​

​

Personal Data (or Data)

It constitutes personal data any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a physical person identified or identifiable.

​

Usage Data

This information is collected automatically through this Application (also from third-party applications integrated into this Application), including IP addresses or domain names of the computers used by the User that connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (good order, error, etc.) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

​

User

The individual who uses this application that, unless otherwise specified, coincides with the interested party.

​

Interested

The natural person to whom the Personal Data refers.

​

Data Processor (or Manager)

The natural person, legal person, public administration and any other entity that processes personal data on behalf of the Owner, as set out in this privacy policy.

​

Data Controller (or Holder)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and use of this application. The Data Controller, unless otherwise specified, is the owner of this Application.

​

This project

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

​

Service

The Service provided by this Application is defined in the relevant terms (if any) on this site/application.

​

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be extended to all current member states of the European Union and the European Economic Area.

​

Cookie

A small portion of data stored in the User's device.

​

Legal references

This privacy statement is drawn up based on multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement only concerns this project.

​​

 

Last modification: 25 May 2018