PRIVACY POLICY

This Privacy Policy is made pursuant to Article 13 of the European Regulation No. 679/2016 and applies exclusively to all Data collected through the textyess.com Website. This Privacy Policy is subject to updates that will be posted on the Website on a timely basis. This Privacy Policy, together with theTerms and Conditions, any other documents referred to in it and the Cookie Policy, establish the basis on which the Data Subject's Personal Data will be processed.

Data Controller

The Data Controller of the Data collected by this Web Site is riccardo@textyess.com

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 Web Site, either independently or through third parties, are Common Data such as: Cookies; Usage Data; Contact Data including name, e-mail, phone number, and shipping and billing address; Login and account information including username, password, and unique user ID; and Payment or credit card information.

Methods of Processing of 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 a free call

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'sown Services and/or Content, via free call to be set up directly on Calendly.

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.

3) Pre-contractual information and fulfillment.

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 an informative nature and/or for information about the purchase of the Data Controller's Services, via free call to be set up directly by Calendly.

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.

4) Processing required as part of a contract.

The Data will be processed in order to fulfill obligations arising from the contract between the Data Subject and the Data Controller for the sale of the Services on the Website, to contact the Data Subject in relation to the Contract and for the management of the Contract, to handle requests for legal guarantees, assistance, requests for withdrawal, management and termination of the Contract

Legal basis: this processing is necessary for the performance of the contract to which the Data Subject is a party, for the execution of pre-contractual measures or to fulfill a legal obligation to which the Data Controller is subject.

Data Retention Period: 10 (ten) years or different legal obligation.

5) Fulfillment of any obligations under applicable laws

The Data will be processed to fulfill any type of obligation contemplated and provided for by current laws, regulations, related rules, business customs, and tax/fiscal matters, including also for the purposes provided for in the anti-money laundering legislation Legislative Decree 231/2007 and subsequent amendments.

Legal basis: this processing is necessary to fulfill a legal obligation to which the Data Controller is subject.

Data Retention Period: 10 (ten) years or different legal requirement.

6) Soft spam

The Data will be processed to allow the Data Controller to send by e-mail to the Interested Party commercial and promotional communications concerning Products and/or Services similar to the Products/Services being sold without the need for the express and prior consent of the Interested Party, as provided for in Article 130, paragraph 4, Privacy Code as amended by Legislative Decree No. 101 of 2018, and provided that the Interested Party does not exercise the right to object.

Legal basis: this processing is based on the legitimate interest of the Data Controller pursuant to Article 6(F) and Recital No. 47 of the GDPR.

Data Retention Period: until opposition by the Data Subject.

7) 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.

8) 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 for in 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: riccardo@textyess.com

Tools used for the Processing of Personal Data

EMAIL ADDRESS MANAGEMENT

These services enable the management of a database of email contacts, telephone contacts, or contacts of any other kind 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.

WEBSITE REGISTRATION

With the registration service, the Data Subject allows the Site to identify him/her and give him/her access to dedicated services. Registration and authentication services can also take place with the help of third parties. In this case, the application may access some Data stored by the third-party service used for registration and identification. The Interested Party registers directly on the site by filling in the Form and providing its Data.

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 (Google Ireland Limited)

Google Analytics 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. IP address anonymization is enabled on this site. The IP address transmitted by your browser for purposes related to Google Analytics will not be merged with other data already held by Google.

At the following link https://tools.google.com/dlpage/gaoptout?hl=it the browser add-on for deactivating Google Analytics is made available by Google. Personal Data Collected: Cookies and Usage Data. Place of processing: 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) Hotjar (Hotjar Ltd)

Hotjar is a statistics service that allows the Data Controller to monitor its customers' conversions and record sessions. A Do not track browser add-on is made available by Hotjar at the following link. Personal Data Collected: Cookies; Usage Data. Place of Processing: Malta - Privacy Policy.

REMARKETING AND RETARGETING

These services allow this Website to communicate, optimize, and serve advertisements based on a DataSubject'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) LinkedIn Insight Tag (LinkedIn Ireland Unlimited Company)

This Website uses a script named "LinkedIn Insight Tag". The LinkedIn Insight Tag adds a cookie toUsers' 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 (link to be activated https://www.linkedin.com/legal/privacy-policy?_l=it_IT)

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. In the event that 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:

Calendly (Calendly LCC)

Calendly is an online automated appointment, call and meeting scheduling software operated by Calendly LCC. Personal Data Collected: Cookies and Usage Data. Place of processing: USA - Privacy Policy

PAYMENT MANAGEMENT

Payment processing services allow this Website to process payments by credit card, bank transfer or other means. The Data used for payment is acquired directly from the operator of the requested payment service without being processed in any way by this Website. Some of these services may also allow the scheduled sending of messages to the Data Subject, such as emails containing invoices or notifications regarding payment. This Website uses the following services:

Stripe (Stripe Payments Europe Ltd.)

Stripe is a payment service provided by Stripe Payments Europe, Ltd. that enables the Data Subject to make online donations or payments using their Stripe credentials. Personal Data collected: Various types of Data as specified by the privacy policy of the service. Place of processing: USA - 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 May 2023