Privacy

Privacy policy of www.samuelefenu.com/

This website collects personal information from its users.

 

This document can be printed for retention purposes by using the “Print” command in the browser.

Provider and responsible person

Samuele Fenu Therapien Zihlmattweg 44 6005 Lucerne – AHV 756.9021.8484.57

Provider’s e-mail address: info@samuelefenu.com

Types of data collected

The personal data that this website processes independently or through third parties includes: Usage data; Trackers; Number of users; City; Device information; Session statistics; Latitude (of city); Longitude (of city); Browser information; First name; Last name; Phone number; Email; Various types of data; Answers to questions; Clicks; Keystrokes; Motion sensor records; Mouse movements; Scroll position; Touch events; Unique device identifier for advertising (Google advertising ID or IDFA, for example).

Full details of each type of personal data processed are provided in the designated sections of this Privacy Policy or selectively through explanatory text displayed prior to data collection.

Personal data may be provided voluntarily by the user or, in the case of usage data, may be collected automatically when this website is used.

Unless otherwise specified, the provision of all data requested by this website is mandatory. If the user refuses to provide the data, this may result in this website being unable to provide its services to the user. In cases where this website expressly states that the provision of personal data is voluntary, users may choose not to provide such data without any consequences for the availability or functioning of the service.

Users who are unsure about which personal data is mandatory may contact the provider.

Any use of cookies – or other tracking tools – by this website or third party service providers used by this website is for the purpose of providing the service requested by the user and any other purposes described in this document and, if available, in the Cookie Policy.

Users are responsible for any third party personal data obtained, published or disclosed through this website and confirm that they have obtained consent to the transfer of any third party personal data to this website.

 

Type and place of data processing

 

Processing methods

 

The Provider processes User Data in a proper manner and takes appropriate security measures to prevent unauthorised access and unauthorised disclosure, alteration or destruction of data.

Data processing is carried out by means of computers or IT-based systems in accordance with organisational procedures and practices that are specific to the stated purposes. In addition to the data controller, other parties may operate this website internally (human resources, sales, marketing, legal, system administrators) or externally – and in that case, where necessary, designated by the data controller as processors (such as technical service providers, delivery companies, hosting providers, IT companies or communication agencies) – and may therefore have access to the data. An up-to-date list of these parties may be requested from the provider at any time.

Legal basis for processing

The provider may only process users’ personal data if one of the following applies:

Users have given their consent for one or more specific purposes. Note: In some jurisdictions, the provider may be permitted to process personal data until the user objects to such processing (“opt-out”) without relying on consent or any other of the following legal bases. However, this does not apply if the processing of personal data is subject to European data protection law;

the collection of data is necessary for the performance of a contract with the user and/or for pre-contractual measures arising therefrom;

the processing is necessary for compliance with a legal obligation to which the provider is subject;

the processing is related to a task carried out in the public interest or in the exercise of official authority vested in the provider;

the processing is necessary to protect the legitimate interests of the provider or a third party.

In any case, the provider will be happy to provide information on the specific legal basis on which the processing is based, in particular whether the provision of personal data is a legal or contractual obligation or a prerequisite for the conclusion of a contract.

Location

Data is processed at the Provider’s office and at any other location where the entities involved in data processing are located.

 

Depending on the location of the users, data transfers may involve the transfer of the user’s data to a country other than their own. To find out more about where the transferred data is processed, users can consult the section detailing the processing of personal data.

Users also have the right to be informed about the legal basis of the transfer of data to a country outside the European Union or to an international organisation governed by international law or established by two or more countries, such as the UN, and about the security measures taken by the provider to protect their data.

 

If such a transfer takes place, the user can find out more by reviewing the relevant sections of this document or by contacting the provider using the information provided in the contact section.

 

Storage period

 

Personal data is processed and stored for as long as required by the purpose for which it was collected.

Therefore:

Personal data collected for the purposes of fulfilling a contract concluded between the provider and the user will be stored until the complete fulfilment of that contract.

Personal data collected for the purpose of safeguarding the provider’s legitimate interests will be retained for as long as is necessary for the fulfilment of those purposes. Users can obtain more information about the Provider’s legitimate interests in the relevant sections of this document or by contacting the Provider.

In addition, the provider is permitted to store personal data for a longer period of time if the user has consented to such processing, as long as the consent is not revoked. Furthermore, the provider may be obliged to store personal data for a longer period of time if this is necessary to fulfil a legal obligation or by order of an authority.

 

After the retention period has expired, personal data will be deleted. Therefore, the right to information, the right to deletion, the right to rectification and the right to data portability cannot be exercised after the retention period has expired.

 

Purposes of processing

Personal data about the User is collected to enable the Provider to provide the Service and further to comply with its legal obligations, to respond to enforcement requests, to protect its rights and interests (or those of Users or third parties), to detect malicious or fraudulent activities. In addition, data is collected for the following purposes: Viewing content from external platforms, tag management, analytics, contacting the user, managing contacts and sending messages, interacting with data collection platforms and other third parties, interacting with external social networks and platforms, SPAM protection, advertising and remarketing and behavioural targeting.

Users can find more detailed information on these processing purposes and the personal data used for each purpose in the “Detailed information on processing of personal data” section of this document.

Detailed information on the processing of personal data

Personal data are collected for the following purposes using the following services:

 

Analytics

 

The services listed in this section allow the Provider to monitor and analyse traffic and track user behaviour.

Google Analytics 4

Google Analytics 4 is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Provider manages data processing (“Google”).

Google uses the data collected to track and study how this website is used, to compile reports on its activities and to share them with other Google services.

Google may use the data collected to contextualise and personalise the ads of its own advertising network. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is stored in a data centre or on a server. Users can learn more by reviewing Google’s official documentation.

Personal data processed: Number of users; Latitude (of city); Browser information; Device information; Longitude (of city); Usage data; Session statistics; City; Tracker.

Processing location: United States – privacy policy – opt out; Ireland – privacy policy – opt out.

Google Ads Conversion Tracking.

Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages data processing, which links data from the Google Ads advertising network to actions taken through this website.

Personal data processed: Usage data; Trackers.

Processing Location: United States – Privacy Policy; Ireland – Privacy Policy.

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. Through the integration of the Meta Pixel, Meta Events Manager may provide the provider with insights into traffic and interactions to this website.

Personal data processed: Usage data; trackers.

Processing Location: Ireland – Privacy Policy.

 

Viewing content from external platforms

 

This type of service allows users to view and interact with content hosted on external platforms directly through this website.

This type of service may still collect web traffic data for the pages on which the service is installed, even if users do not use it.

Google Fonts

Google Fonts is a font visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages the data processing, which allows this website to embed relevant content on its pages.

Personal data processed: Usage data; Tracker.

Processing location: United States – privacy policy; Ireland – privacy policy.

Instagram widget

Instagram is an image visualisation service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the provider manages data processing, which allows this website to embed relevant content on its pages.

Personal data processed: Usage data; trackers.

Processing Location: United States – Privacy Policy; Ireland – Privacy Policy.

Adobe Edge Web Fonts (Adobe Systems Incorporated)

Adobe Edge Web Fonts is a font visualisation service provided by Adobe Systems Incorporated that allows this website to embed related content on its pages.

Personal data processed: Usage data; various types of data as described in the privacy policy of the service.

Processing Location: United States – Privacy Policy.

Adobe Fonts (Adobe Systems Incorporated).

Adobe Fonts is a font visualisation service provided by Adobe Systems Incorporated that allows this website to embed related content on its pages.

Personal data processed: Usage data; various types of data as described in the privacy policy of the service.

Processing Location: United States – Privacy Policy.

Font Awesome (Fonticons, Inc. ).

Font Awesome is a font visualisation service provided by Fonticons, Inc. that allows this website to embed related content on its pages.

Personal data processed: Usage data; trackers.

Processing Location: United States – Privacy Policy.

Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)

Fonts.com Web Fonts is a font visualisation service provided by Monotype Imaging Holdings Inc. that allows this website to embed related content on its pages.

Personal data processed: Usage data; trackers.

Processing Location: United States – Privacy Policy.

MyFonts (Monotype Imaging Holdings Inc.)

MyFonts is a font visualisation service provided by Monotype Imaging Holdings Inc. that allows this website to embed related content on its pages.

Personal data processed: Usage data; trackers.

Processing Location: United States – Privacy Policy.

Vimeo Video (Vimeo, LLC)

Vimeo is a video content visualisation service provided by Vimeo, LLC that allows this website to embed relevant content on its pages.

Personal data processed: Usage data; Trackers.

Processing Location: United States – Privacy Policy.

 

 

 

Interaction with data collection platforms and other third parties

 

These types of services allow users to interact with data collection platforms or other third parties directly from the pages this website contains for the purpose of storing and reusing data.

If a relevant service is installed, it may be able to collect navigational and usage data on the pages on which it is installed even if users are not actively using the service.

MailChimp widget (Intuit Inc.).

The MailChimp widget is a service which allows you to interact with the Mailchimp email and messaging service provided by Intuit Inc.

Personal data processed: Email; Tracker.

Processing Location: United States – Privacy Policy.

Interaction with external social networks and platforms.

 

These types of services allow interaction with social networks or other external platforms directly through this website.

The interaction, as well as the information collected through this website, is always subject to the privacy settings made by the users for the respective social network.

This type of service may continue to collect web traffic data for the sites where the service is installed, even if users do not use it.

It is recommended to log out of the respective services to ensure that the processed data is not reconnected to the user’s profile through this website.

AddToAny (AddToAny LLC).

AddToAny is a widget display service provided by AddToAny LLC that allows users to interact with social networks and external platforms, as well as share the content that this website contains.

Depending on the settings, this service may display third-party widgets – for example, the leaders of social networks where interactions are shared. In this case, the third party providers of the widget will also be notified of the interactions and usage data of the pages where the service is installed.

Data collected through this service may be used to serve interest-based advertising. Users may opt-out of receiving interest-based advertising from third parties via the Network Advertising Initiative opt-out page.

Personal data processed: Usage data; trackers.

Processing Location: United States – Privacy Policy.

 

Contacting the user

 

Contact form (this website)

By filling in the contact form with their details, users authorise this website to use their details to respond to requests for information, quotations or other enquiries specified in the header of the form.

Personal data processed: Email; surname; telephone number; tracker; various types of data; first name.

Remarketing and behavioural targeting

 

This type of service allows this website and its partners to analyse how this website has been used in previous sessions by the user in order to target, optimise and deploy advertising.

This activity is facilitated by tracking usage data and the use of trackers that collect information which is then transmitted to the partners who manage the remarketing and behavioural targeting activities.

Some services offer a remarketing option based on email address lists.

Services of this type usually offer the option to opt-out of such tracking. In addition to any opt-out feature offered by the services below, users can learn more about how to opt-out of interest-based advertising in general in the relevant “How to opt-out of interest-based advertising” section of this document.

Google Ads Remarketing

Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages the data processing that links activity from this website to the Google Ads advertising network and the DoubleClick cookie. To learn more about Google’s data use, please refer to Google’s partner policy. Users can opt out of Google’s use of trackers by accessing Google’s ads settings.

Personal data processed: Usage data; Trackers.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

 

 

SPAM protection

 

These types of services analyse traffic that passes through this website and may contain personal data of users in order to filter out parts of the traffic, messages and content that are considered SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages data processing.

The use of reCAPTCHA is subject to Google’s privacy policy and terms of use.

Personal data processed: Responses to questions; motion sensor records; mouse movements; clicks; usage data; scroll position; keystrokes; touch events; trackers.

Processing location: United States – privacy policy; Ireland – privacy policy.

Tag Management

 

These types of services help the provider centrally manage the tags or scripts required for this website.

This results in the user’s data flowing through these services and potentially being stored.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages the data processing.

Personal data processed: Usage data; Trackers.

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

 

 

Managing Contacts and Sending Messages

 

These types of services allow the management of a database of email contacts, phone numbers or any other contact information in order to communicate with the user.

The services may also collect data about the date and time messages are read by the user and when the user interacts with incoming messages, for example by clicking on links contained within them.

Mailchimp (Intuit Inc.)

Mailchimp is an email address management and messaging service provided by Intuit Inc.

Personal data processed: Email; various types of data.

Processing location: United States – Privacy Policy.

 

 

Advertising

 

This type of service allows the use of user data for advertising purposes. Promotional messages are displayed through this website in the form of banners and other advertisements and may be customised based on behaviour. This does not mean that all personal data will be used for this purpose. Further information and terms of use are set out below.

Some of the services listed below may use trackers to identify users or use behavioural retargeting. This method can also be used to identify the interests and surfing behaviour of users who do not take place via this website, in order to target advertisements accordingly. For more information, please refer to the privacy statements of the respective services.

Services of this type usually offer the option to opt out of such tracking. In addition to each opt-out feature offered by the services below, users can learn more about how to opt-out of interest-based advertising in general in the relevant “How to opt-out of interest-based advertising” section of this document.

Google AdSense

Google AdSense is an advertising service provided by Google LLC or Google Ireland Limited, depending on how the provider manages data processing. This service uses the “DoubleClick” cookie to track how this website is used and how users respond to advertisements and products and services offered.

Users can choose to disable all DoubleClick cookies by visiting this page: Advertising Preferences. To learn more about Google’s data use, please refer to Google’s partner policy.

Personal data processed: Usage data; Trackers.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ads similar audiences

Google Ads similar targeting is an advertising and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the provider manages the data processing, which uses data from Google Ads Remarketing to serve ads to users with similar behaviour who are already on the remarketing list based on their previous use of this website.

Based on this data, personalised ads are displayed to users suggested by Google Ads similar audiences. Users who do not wish to be included in Google Ads similar audiences can opt-out and disable the use of advertising cookies: Google Ads Settings. To learn more about Google’s data use, please refer to Google’s partner policy.

Personal data processed: Usage data; Trackers.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Meta Audience Network

Meta Audience Network is an advertising service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the provider manages data processing, For more information on Facebook’s use of data, please see Facebook’s Data Policy. This website uses mobile device identifiers (including Android Advertising ID or Advertising Identifier for iOS) and cookie-like technologies to run the Meta Audience Network service. One of the display options for Audience Network ads is through the user’s advertising preferences. Users can set this under Facebook’s ad settings. Users may opt out of certain Audience Network targeting through the appropriate device settings, such as through the device’s advertising settings on mobile phones or by following the instructions in other sections of this Privacy Policy regarding Audience Network, as applicable.

Personal Data Processed: Unique device identifier for advertising (Google advertising ID or IDFA, for example); usage data; trackers.

Processing Location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

 

 

Information on opting out of interest-based advertising

 

In addition to any opt-out provided by the services listed in this document, users may follow the guidance provided by YourOnlineChoices (EU), the Network Advertising Initiative (USA) and the Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow users to choose their tracking settings for most advertising tools. The Provider thus recommends users to make use of these tools in addition to the information provided in this document.

The Digital Advertising Alliance offers the application ” AppChoices ” to control interest-based advertising in mobile apps.

Users can also object to certain advertising features via the relevant device settings, e.g. via the device settings for advertising on mobile devices or via the general advertising settings.

 

 

The rights of users

 

Users may exercise certain rights in relation to their data processed by the Provider.

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

Revoke consents at any time. If the user has previously consented to the processing of personal data, they may withdraw their own consent at any time.

Object to the processing of their data. The user has the right to object to the processing of their data if the processing is based on a legal basis other than consent. Further information on this is provided below.

Obtain information regarding their data. The user has the right to know whether the data is being processed by the provider, to be informed about individual aspects of the processing and to receive a copy of the data.

Have it checked and corrected. The user has the right to check the accuracy of their data and request that it be updated or corrected.

Request restriction of the processing of their data. Users have the right to restrict the processing of their data in certain circumstances. In this case, the provider will not process the data for any purpose other than storage.

Request erasure or other removal of personal data. Users have the right, in certain circumstances, to request that their data be erased by the provider.

Receive their data and have it transferred to another data controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically possible, to have it transferred to another controller without hindrance. This provision applies where the data is processed by automated means and the processing is based on the user’s consent, on a contract to which the user is party or on pre-contractual obligations.

Submitting a complaint. Users have the right to lodge a complaint with the competent supervisory authority.

Details of the right to object to processing

Where personal data are processed in the public interest, in the exercise of a sovereign power conferred on the provider or to safeguard the provider’s legitimate interests, the user may object to such processing by providing a justification relating to his or her particular situation.

Users are informed that they may object to the processing of personal data for direct marketing at any time without giving reasons. Users can find out whether the provider processes personal data for direct marketing purposes in the relevant sections of this document.

How the rights can be exercised

All requests to exercise user rights can be made to the provider using the contact details provided in this document. Requests can be exercised free of charge and will be dealt with by the provider as soon as possible and within one month at the latest.

 

 

Further information on the collection and processing of data

 

Legal measures

The User’s personal data may be processed by the Provider for law enforcement purposes within or in preparation of legal proceedings arising from the improper use of this Website or its associated services.

The user declares that he/she is aware that the provider may be required by the authorities to hand over personal data.

Further information about the user’s personal data

In addition to the information set out in this Privacy Policy, this website may provide the User, upon request, with further contextual information relating to specific services or to the collection and processing of personal data.

System Protocols and Maintenance

For operational and maintenance purposes, this website and third party services may collect files that record interaction that takes place through this website (system logs) or use other personal data (e.g. IP address) for this purpose.

Information not included in this Privacy Policy

Further information about the collection or processing of personal data can be requested from the provider at any time using the contact details listed.

How “Do Not Track” requests are handled

This website does not support Do Not Track requests by web browsers.

For information on whether integrated third-party services support the Do Not Track protocol, users should refer to the privacy policy of the relevant service.

Changes to this privacy policy

The provider reserves the right to make changes to this privacy statement at any time by notifying users on this page and, where appropriate, via this website and/or – where technically and legally possible – by sending a message to users’ contact details held by the provider. Users are therefore advised to consult this page regularly and in particular to check the date of the last modification indicated at the bottom of the page.

 

Insofar as changes affect a data use based on the user’s consent, the provider will – insofar as necessary – obtain a new consent.

 

 

Definitions and legal information

 

Personal data (or data)

Any information by which the identity of a natural person is or can be determined, directly or in combination with other information.

Usage data

Information that this website (or third party services that this website uses) automatically collects, such as: the IP addresses or domain names of the computers of users who use this website, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to send the request to the server, the size of the response file received, the numerical code indicating the status of the server response (successful result, error, etc.), the country of origin, the functions of the computer used by the user, the type of computer used, the type of software used, the type of software used, etc.). ), the country of origin, the functions of the browser and operating system used by the user, the various time data per call (e.g. how much time was spent on each page of the application) and information about the path followed within an application, in particular the order of the pages visited, as well as other information about the operating system of the device and/or the IT environment of the user.

User

The person using this website who, unless otherwise specified, is the same as the data subject.

Data subject

The natural person to whom the personal data relates.

Processor (or data processor)

Natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller as described in this privacy statement.

Controller (or provider, sometimes also 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 and the means used for that purpose, including the security measures relating to the operation and use of this website. Unless otherwise specified, the controller is the natural or legal person through whom this website is offered.

This website (or application)

The hardware or software tool used to collect and process the user’s personal data.

Service

The service offered through this website as described in the relevant T&Cs (if any) and on this website/application.

European Union (or EU)

Unless otherwise stated, all references in this document to the European Union are to all current Member States of the European Union and the European Economic Area (EEA).

Cookie

Cookies are trackers consisting of a small data set stored in the user’s browser.

Tracker

The term tracker refers to any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags or fingerprinting – that can track users, for example by enabling access to or storage of information on the user’s device.

Legal notice

This Privacy Policy has been drafted based on provisions of various legislations, including Article 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy statement applies solely to this website, unless otherwise stated in this document.

 

 

 

Last updated: 22 November 2022

 

iubenda hosts this content and only collects the personal data that is strictly necessary to provide it.

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