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Privacy Policy

This Privacy Policy is made pursuant to Article 13 of European Regulation No. 679/2016 and applies exclusively to all Data collected through the Website www.centumbrie.com. This Privacy Policy is subject to updates that will be posted timely on the Website. This Privacy Policy and the Cookie Policy, establish the basis on which the Personal Data of the Data Subject will be processed.

Data Controller

The Data Controller of the Data collected from this Web Site is CM srl, located in Agello - Magione (PG), via Osteria San Martino 31/C (VAT / Tax Code: 035545590541), email: cmcasamia@centumbrie.com

Web platform

The website is built with GRAV platform which is intended to host and operate key components of the same. These platforms may provide analytical tools, user registration management, comment and database management, e-commerce, payment processing etc. The use of such tools involves the collection and processing of Personal Data.
Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.
The Platform chosen by the Owner is:

GRAV

Grav is an Open Collective licensed Web platform.

Personal Data

Personal Data means any information concerning an identified or identifiable natural person (Data Subject). An identifiable natural person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, one or more characteristic elements of his or her physical identity.

Category of Personal Data Processed 

Among the Personal Data processed by this Website, either independently or through third parties, are Common Data such as: Cookies, Usage Data, Contact Data including name, e-mail.

Methods of Processing Personal Data

The Personal Data provided or acquired will be subject to Processing based on the principles of fairness, lawfulness, transparency and protection of confidentiality in accordance with current regulations. The Data Controller processes Users' Personal Data by adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The Processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes.

Purpose of the Processing of Personal Data and Legal Basis

Personal Data may be collected autonomously by the Data Controller or through third parties. In this case, the computer systems and software procedures in charge of the operation of this Website acquire certain Personal Data of the Users, of a technical-informatics nature (e.g. IP address, type of browser used, operating system, domain name and addresses of websites from which access or exit was made, etc.), the transmission of which is inherent to the normal operation of the Internet. Such Data may be processed for the sole purpose of obtaining anonymous statistical information on the use of the site and/or to check its correct functioning and will be deleted immediately after processing.
The Data that the Data Subject chooses to voluntarily provide will be processed in compliance with the conditions of lawfulness under Article 6 GDPR and will be processed to enable the Website to provide its services, as well as for the Purposes indicated below and will be kept for the time necessary for the fulfillment of the aforementioned Purposes.
The Purposes of the processing are:

1) Responding to inquiries and providing Information

The Data will be processed for the purpose of being contacted or following up on specific requests made to the Data Controller by the Data Subject for communications of a nature relating to the Data Controller's own Services and/or Content, via e-mail messages or other means of communication such as telephone.
Legal basis: this processing is optional and based on the consent of the Data Subject, however, the provision of the Data is necessary for the pursuit of the stated purpose.
Data retention period: until consent is revoked by the Data Subject.

2) Newsletter

The Data will be processed for sending promotional, commercial and advertising communications and material or inherent to initiatives and events of the Data Controller, through newsletters.
Legal basis: this processing is based on the consent freely given by the Data Subject in accordance with Article 6(1)(A) of the GDPR.
Data Retention Period: until consent is revoked by the Data Subject through the appropriate tool at the bottom of the newsletter or through a request to the Data Controller.

3) Statistics

The Data will be processed to perform statistical analysis on aggregated and anonymous data to analyze the behavior of the Data Subject in order to improve the products and services provided by the Data Controller as well as to meet the Data Subject's expectations.
Legal basis: this processing is based on the consent freely given by the Data Subject.
Data retention period: until consent is revoked by the Data Subject.

4) Profiling

Data will be processed for the analysis and evaluation of interests, habits, consumption choices, including the creation of profiles in order to be able to send personalized informative and promotional material about the Services/Products offered by the Data Controller. 
Legal basis: this processing is based on the consent freely given by the Data Subject in accordance with Article 6(1)(A) of the GDPR.
Data retention period: until consent is revoked by the Data Subject.

Disclosure of Data

In addition to the Owner, in some cases, they may have access to the Data:
(a) categories of specially trained appointees involved in the organization of the Website (administrative, sales, marketing, legal, system administrators); 
b) external parties (such as third party technical service providers, hosting providers, IT companies, communication agencies) also appointed as Data Processors by the Data Controller ex art. 28 GDPR. The updated list of Data Processors, if appointed, can always be requested from the Data Controller; 
(c) public or private entities that can access the Data in compliance with legal obligations; 
(d) individuals who perform tasks that are ancillary and instrumental to the Holder's activity;

Timing of Treatment

As expressly provided by art. 5, co. 1, letter e) of the GDPR, the Data are kept for the time necessary for the Processing of the same in relation to the performance of the service requested by the Data Subject, or required by the Purposes described above in this document. At the end of the retention period, the Personal Data will be deleted and therefore, the rights of access, deletion, rectification and portability of the Data can no longer be exercised.

Cookie

This Website uses cookies. Cookies are small text files that can be used by Websites to make the experience more efficient for the Data Subject and to personalize content and ads, provide social media features, and analyze traffic. Cookie Policy

Place of Processing and Transfer of Data Abroad

The Data are processed at the operational headquarters of the Data Controller. For further information you may contact the Data Controller. The Data may be processed by individuals and/or legal entities operating on behalf of the Data Controller and under specific contractual obligations and located in EU or non-EU member countries. In the event that Data is transferred outside the EEA, the Data Controller will take all appropriate contractual measures to ensure adequate protection of the Data.

Exercise of data subject's rights

The Data Subject has the right to exercise the faculties provided for in Articles 7, 15-22 of European Reg. 679/2016.  In particular, he/she has the right to revoke his/her consent at any time and, upon simple request to the Data Controller, he/she may request access to the Personal Data, receive the Personal Data provided to the Data Controller and where possible transmit them to another Data Controller without hindrance (so-called portability), obtain the updating, limitation of the processing, rectification of the Data and the deletion of those processed in breach of the regulations in force. He/she has the right, for legitimate reasons, to object to the Processing of Personal Data concerning him/her and to the Processing for purposes of sending advertising material, direct sales and for carrying out market research. He/she also has the right to lodge a complaint with the Privacy Guarantor as the supervisory authority for the protection of personal data or to take appropriate legal action. The data subject may exercise his or her rights by contacting the Data Controller by e-mail at: cmcasamia@centumbrie.com.

Tools used for the Processing of Personal Data

CONTACT FORM 

The Interested Party, by filling out the Contact Form with their Data, consents to their use to respond to requests for information, or any other purpose indicated by the header of the form. Personal Data collected through Contact Form: Email and Name.
This website uses:

EMAIL ADDRESS MANAGEMENT

These services enable the management of a database of email contacts, telephone contacts, or contacts of any other type used to communicate with the Data Subject. These services may also allow for the collection of Data related to the date and time of viewing of messages by the Data Subject, as well as the Data Subject's interaction with them, such as information about clicks on links embedded in messages.

Newsletter

By registering for the newsletter, the Data Subject's email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, relating to this Web Site may be sent. The Data Subject's email address may also be added to this list as a result of registering with this Website or after making a purchase. The Interested Party may choose at any time to unsubscribe from the newsletter by clicking on a specific button they will find within the emails. After clicking the unsubscribe button the Data Subject's Data will be deleted immediately from the "email marketing" software. Personal Data collected: email and Name. This Website uses the newsletter service provided by:

Brevo ex SendinBlue (SendinBlue SAS)

Brevo is a service that organizes and analyzes newsletter distribution. In case a Data Subject does not want their Data to be handled by Brevo, it will be necessary for them to unsubscribe from the newsletter. For this purpose, a link is provided in each newsletter sent. Personal Data Collected: Email and Name. Place of Processing: FRANCE  – Privacy Policy 

SPAM PROTECTION AND SECURITY MEASURES

This Website, to make it secure when Personal Data is entered, has an SSL certificate and uses the HTTPS protocol. With the use of this protocol, the transactions and data that are transmitted in the Websites take place with maximum security and the content of the communication is not read or manipulated in any way by third parties.
This website also uses tools that analyze traffic potentially in order to filter it from parts of traffic, messages and content recognized as SPAM.

reCAPTCHA

This Website uses reCAPTCHA which is a service subject to the privacy policy and terms and conditions.

STATISTICS

Statistical services allow the Data Controller exclusively to monitor and analyze traffic data and are used to track the behavior of the Data Subject. This Website uses the following services:

1) Google Analytics 4

Google Analytics is an analytics service provided by Google LLC. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its advertising network. Google may also transfer this information to third parties where required by law or where such third parties process this information on Google's behalf. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult Google's official documentation. At the following link https://tools.google.com/dlpage/gaoptout?hl=it the browser add-on for disabling Google Analytics is made available by Google. Personal Data Collected: Cookies and Usage Data. Place of processing: USA - Ireland Privacy Policy

2) Facebook pixel conversion tracking (Meta Platforms, Inc.)

Facebook conversion tracking (Facebook pixel) is a statistics service provided by Facebook. The Facebook pixel monitors conversions that can be attributed to Facebook ads. Personal data collected: Cookies; Usage data. Place of processing: Ireland - Privacy Policy.

3) Monitoring LinkedIn pixel conversions (LinkedIn Ireland Unlimited Company)

LinkedIn's conversion tracking (LinkedIn pixel) is a statistics service provided by LinkedIn. The LinkedIn pixel monitors conversions that can be attributed to the advertisements of. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy 

4) Monitoring Instagram pixel conversions (Meta Platforms, Inc.)

Instagram's conversion tracking (Instagram pixel) is a statistics service provided by Meta Platforms, Inc. The Instagram pixel monitors conversions that can be attributed to Facebook ads. Personal data collected: Cookies; Usage data. Place of processing: Ireland - Privacy Policy 

5) Google Search Console (Google Ireland Limited)

is an analytics service provided by Google Ireland Limited. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its advertising network. Google may also transfer this information to third parties where required to do so by law or where such third parties process this information on Google's behalf. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy 

6) Monitoring pixel conversions by Tik Tok (Tik Tok Ireland)

Tik Tok Conversion Tracking is a statistics service that allows the Data Controller to track the conversions of its customers. Personal Data Collected: Cookies; Usage Data. Place of processing: Ireland - Privacy Policy 

7) Pinterest pixel conversion tracking (Pinterest Europe Ltd.)

Pinterest Conversion Tracking (Pinterest pixel) is a statistics service that allows the Data Controller to track the conversions of its customers. Personal Data Collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy 

8) Google Tag Manager (Google Ireland Limited)

Tag Manager is a service provided by Google that allows you to monitor and manage your site's tags, enabling better site indexing. Place of Processing: Ireland - Privacy Policy 

INTERACTION WITH SOCIAL NETWORKS

These services allow for interactions with social networks directly from the pages of this Website. Interactions and information captured by this Website are in each case subject to the privacy settings of the Data Subject related to each social network. In the event that a social network interaction service is installed, it is possible that, even if Users do not use the service, it will collect traffic data related to the pages where it is installed. 

1) Facebook (Meta Platforms, Inc.)

Facebook buttons are interaction services with the social network Facebook, provided by Meta Platforms, Inc. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy 

2) Instagram (Meta Platforms, Inc.)

Instagram buttons are interaction services with the social network Instagram, provided by Meta Platforms, Inc. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy 

3) LinkedIn (LinkedIn Ireland Unlimited Company)

LinkedIn buttons are services for interaction with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy 

4) Twitter (Twitter International Company)

Twitter buttons are services for interaction with the social network Twitter, provided by Twitter, Inc. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland - Privacy Policy 

5) Pinterest (Pinterest Europe Ltd)

Pinterest buttons are interaction services with the social network Pinterest, provided by Pinterest, Inc. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland - Privacy Policy 

6) Twitter for Websites

Twitter for Websites is a suite of products that allow the publisher of this Website to embed Twitter content on their Website. These products include embedded Tweets, embedded timelines, Tweet buttons, and Follow buttons. Place of Processing: Ireland – Privacy Policy 

7) Telegram (Telegram UK Holdings Ltd)

Telegram buttons are communication interaction services provided by Telegram. Personal Data Collected: Cookies and Usage Data. Place of processing: UK- – Privacy Policy 

8) Tik Tok (TikTok Technology Limited)

Tik Tok buttons are social network interaction services provided by TikTok Technology Limited. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy 

REMARKETING AND RETARGETING

These services allow this Website to communicate, optimize, and serve advertisements based on a Data Subject's past use of this Website. This activity is done by tracking Usage Data and the use of Cookies. This Web Site uses the following services:

1) Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, which links this Website's activity with the Facebook advertising network. This Website makes use of the Facebook Pixel tool in order to measure conversions. Thanks to the Facebook Pixel you can understand the actions that people perform on the Website. The Data that is collected can be used to:
- Make sure listings are shown to the right people;
- Create audience groups for which to target advertisements;
- Take advantage of the additional advertising tools of the platform you are advertising on
The information collected is anonymous to the operators of this Site and cannot be used to identify an individual Data Subject. However, the information is saved and analyzed by Facebook, which could link the action back to an individual profile and use this information for internal Facebook advertising purposes, as outlined by Facebook's privacy policy. This will allow Facebook to show advertisements on both Facebook and third-party sites. The Site Owner has no control over how this data is used. For more information on how users can protect their privacy, please refer to Facebook's Privacy Policy

2) Google ADS

Google ADS is a service provided by Google Ireland Limited that links this Website with Google's advertising network. This Web Site makes use of the Remarketing functionality of Google Analytics combined with the cross-device adaptability of Google ADS. This functionality makes it possible to connect target groups for promotional campaigns created by the Marketing function of Google Analytics with the adaptability to different Google ADS devices. This makes it possible to show advertisements based on the Respondent's personal interests, identified through an analysis of the Respondent's web behavior, whether on a mobile device or other devices. You can permanently disable targeting and remarketing features by disabling the "personalized advertising" feature in your Google account. To do so, simply follow this link: https://www.google.com/settings/ads/onweb/ Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy 

3) LinkedIn Insight Tag (LinkedIn Ireland Unlimited Company)

This Website uses a script named "LinkedIn Insight Tag". The LinkedIn Insight Tag adds a cookie to Users' browsers each time they visit this Website. Using this tool, the Owner can record when a LinkedIn member performs a certain action on the Website (such as booking a service or leaving email). This tool is used for collecting statistical data to measure the effectiveness of paid advertising. Using the LinkedIn Insight Tag, one can understand the actions that people perform on the Website. The Data collected is used to: make sure ads are shown to the right people; create audience groups to target ads to; take advantage of the platform's additional advertising tools on you advertise. This Website uses the LinkedIn Insight Tag to perform "remarketing" and "Retargeting" activities; thanks to these activities, cookies that the Data Subject leaves on the Website are used, but without identifying him or her. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland-  – Privacy Policy 

CONTENT ON EXTERNAL PLATFORMS 

These services allow to display content hosted on external platforms directly from the pages of this Website and interact with them.
 Where such a service is installed, it is possible that, even if Users do not use the service, it will collect Traffic Data related to the pages where it is installed.
This Web Site uses 

1) Vimeo (Vimeo Inc.)

Vimeo is a video content display service operated by Vimeo Inc. that allows this Application to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of Processing: USA – Privacy Policy 

2) Youtube (Google Ireland Limited)

Youtube is a video content display service operated by Google that allows this Website to integrate such content within its pages. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy 

3) Google Fonts

Google Fonts is a font style display service provided by Google Ireland Limited that enables this Web Site to integrate such content within its pages. Personal Data collected: Usage Data; various types of Data as specified by the privacy policy of the service. Place of processing: Ireland – Privacy Policy 

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Therefore, please consult this page often, taking as reference the date of last modification indicated at the bottom. If you do not accept the changes made to this Privacy Policy, you must cease using this Website and may request the Data Controller to remove your Personal Data. Unless otherwise specified, the previous Privacy Policy will continue to apply to the Personal Data collected up to that point. The Data Controller is not responsible for updating all links viewable in this Privacy Policy, so whenever a link is not working and/or updated, Users acknowledge and agree that they should always refer to the document and/or section of the websites referred to by that link.

Privacy Policy updated as of October 2023