Privacy Policy
This Application collects certain Personal Data from its Users.
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Data Controller
Beauty Learn – Suggerimente S.r.l. a S.U.
Via Monte Napoleone, 8 – Milano (MI) – VAT No. 12624250960 – PEC: suggerimente@pec.it
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, there are: Tracking Tools; Usage Data; number of Users; city; device information; session statistics; latitude and longitude (of the city); browser information; email; first name; last name; date of birth; physical address; country; phone number; ZIP code; gender; state; company name; marital status; profession; Data provided while using the service; fax number; Tax ID; User ID; number of employees; unique device identifiers for advertising (such as Google Advertiser ID or IDFA); UUID; responses to questions; clicks; keypress events; motion sensor data; mouse movements; scroll position; and touch events.
Complete details on each type of collected Personal Data are provided in the dedicated sections of this privacy policy or through specific explanatory texts displayed before the Data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. Where this Application specifically states that some Data is not mandatory, Users are free not to communicate such Data without consequences on the availability or functioning of the Service.
The use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application serves to provide the Service requested by the User, in addition to the other purposes described in this document and the Cookie Policy.
The User is responsible for any third-party Personal Data obtained, published, or shared through this Application.
Methods and Place of Data Processing
Processing Methods
The Data Controller adopts 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 logics strictly related to the stated purposes. In some cases, Data may be accessible to certain persons 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, communication agencies) appointed, if necessary, as Data Processors by the Controller. The updated list of these parties may be requested from the Data Controller at any time.
Location
Data is processed at the Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller.
Personal Data may be transferred to a country other than the one in which the User is located. Users can refer to the section on details about Personal Data processing for further information.
Retention Time
Unless otherwise specified in this document, Personal Data is processed and stored for as long as required by the purpose for which it was collected. It may also be retained for a longer period due to legal obligations or based on User consent.
Purpose of Data Processing
User Data is collected to allow the Controller to provide the Service, comply with legal obligations, respond to enforcement requests, protect its rights and interests (or those of Users or third parties), detect malicious or fraudulent activity, as well as for the following: Statistics, Remarketing and behavioral targeting, Advertising, Data collection and online survey management, Heat mapping and session recording, Contacting the User, Displaying content from external platforms, Tag management, and Anti-SPAM protection.
Users may refer to the section “Details on Personal Data Processing” for more detailed information.
Details on Personal Data Processing
Personal Data is collected for the following purposes using the following services:
Contacting the User
Tag management
Data collection and online survey tools
Heat mapping and session recording
Anti-SPAM protection
Advertising
Remarketing and behavioral targeting
Statistics
Displaying content from external platforms
Opt-out from Interest-Based Advertising
In addition to any opt-out offered by any of the services listed in this document, Users may learn more about how to generally opt out of interest-based advertising by referring to the appropriate section in the Cookie Policy.
Cookie Policy
This Application uses Tracking Tools. For more information, Users may refer to the Cookie Policy.
Additional User Information
Legal Basis for Processing
The Controller may process Personal Data if one of the following applies:
The User has given consent for one or more specific purposes.
Processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations.
Processing is necessary for compliance with a legal obligation.
Processing is related to a task carried out in the public interest or in the exercise of official authority.
Processing is necessary for the legitimate interests pursued by the Controller or a third party.
Users may contact the Controller to clarify the specific legal basis that applies to each processing operation.
Data Retention Details
Unless otherwise specified in this document:
Personal Data collected for the performance of a contract will be retained until the contract is fully executed.
Personal Data collected for the Controller’s legitimate interest will be retained as long as needed to fulfill such interest.
When processing is based on User consent, the Controller may retain the data until consent is withdrawn.
The Controller may also be obliged to retain Personal Data for a longer period to comply with legal obligations or by order of an authority.
Once the retention period expires, the Personal Data will be deleted. Thus, rights such as access, deletion, rectification, and data portability can no longer be exercised once the retention period has ended.
User Rights under GDPR
Users may exercise certain rights regarding their Data processed by the Controller. Specifically, Users have the right to:
Withdraw consent at any time;
Object to processing of their Data;
Access their Data;
Verify and request rectification;
Restrict the processing of their Data;
Have their Personal Data deleted or otherwise removed;
Receive their Data and have it transferred to another controller;
Lodge a complaint with their data protection authority.
Users have the right to learn if their Data is transferred abroad, including to any international organization governed by public international law (e.g., the UN), and about the security measures taken by the Controller.
Right to Object
Where Personal Data is processed in the public interest or in the legitimate interests of the Controller, Users may object to such processing based on grounds related to their particular situation.
Where Personal Data is processed for direct marketing purposes, Users may object at any time without justification. Upon such objection, the Personal Data will no longer be processed for these purposes.
Exercising User Rights
Any requests to exercise User rights can be directed to the Controller using the contact details provided. Requests are free and will be processed by the Controller as quickly as possible, and always within one month.
Additional Information
Legal Defense
The Controller may use the User’s Personal Data in court or in the stages leading to possible legal action arising from improper use of this Application or related Services.
Specific Information
Upon request, in addition to the information in this privacy policy, this Application may provide the User with additional contextual information concerning particular Services or the collection and processing of Personal Data.
System Logs and Maintenance
For operation and maintenance purposes, this Application and any third-party services may collect system logs—files that record interactions and may contain Personal Data such as the User’s IP address.
Changes to this Privacy Policy
The Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if technically and legally feasible, by sending a notice to Users via any contact information available. It is strongly recommended to check this page often, referring to the date of the last update.
If the changes affect processing based on User consent, the Controller will collect new consent where required.