Privacy Policy 

This Privacy Policy is made pursuant to Art. 13 of European Regulation no. 679/2016 and applies exclusively to all Data collected through the Website www.audaciainnovations.com (hereinafter “Website”).  

This Privacy Policy is subject to updates that will be posted timely on the Website.  

This Privacy Policy together with the Cookie Policy, establishes the basis on which the User’s Personal Data will be processed. 

Data Controller 

The Data Controller of the Data collected from this Website is Audacia Innovation S.r.l. with registered office in Via Eumelo 32, 96100, Syracuse, CF/P.IVA 02062520891, email address legal@audaciainnovations.com 

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 taking appropriate security measures to prevent 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 logic strictly related to the indicated purposes. 

Personal Data may be collected independently by the Owner or through third parties.  

We collect only the information we actually need. 

Some of this is information that you actively provide when you register for an account, an event, request customer support, or purchase something. 

When the User visits one of our Web sites or uses the Data Controller’s software, it automatically records some basic information about how the User arrived at the site, where the User navigated within it, and what features and settings the User used.  

The Owner uses this information to improve Web sites and services and to guide the development of new products. Sometimes the Holder receives information indirectly. 

If the User requests information about the Owner’s products through one of the referral programs or resale partners, or accesses one of the products through an authentication service provider such as LinkedIn or Google, they will transmit the relevant contact information to the Owner. 

If you interact with Holder’s brand on social media (e.g., by liking, commenting, retweeting, quoting, or following), Holder will have access to your interactions and profile information.  

It will still retain this information even if it is later removed from the social media site. 

The Owner uses the information to provide the requested services, create and maintain the account, and monitor unauthorized activity on the accounts.  

They will also be used to communicate with you about the products you are currently using, customer service requests, new products, opportunities for you to provide feedback, and standards updates. 

Analyzes the information we collect to understand user needs and to improve our Web sites and services. 

The Holder is required to have a legal basis for collecting and processing information.  

You can opt out of certain types of information use by not providing the information in the first place or by opting out later. 

It is also possible to disable cookies to prevent the browser from providing information, but then some features of the Web site may not work properly.  

If the Owner shares information with other parties (such as developers, service providers, domain registrars, and resale partners), they must have appropriate security measures in place and a valid reason for using the information.  

The European Economic Area (EEA) guarantees certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and complain). Audacia is committed to providing the same rights regardless of where a user lives.  

The Owner retains your personal information for as long as necessary for the purposes stated in this Privacy Policy. 

Types of personal data collected 

Personal Data may be provided voluntarily by the User when using the Website, when filling out the Contact Form, subscribing to newsletters, through registration, signing the various contracts and through tokens, or when communicating with the Owner via email or telephone. 

 Personal Data provided or acquired may be of various types including: 

• Contact information such as name, residence, date of birth (if explicit), gender (if explicit), e-mail address; 

• Email data (e.g., the number of times the email was opened); 
• Details payment and billing details; 
• Profile images used in various platforms and posted on social media; 
• Statistics provided by platforms, e.g., number of streams, number of subscribers, posts and engagement, socio-demographic data of each User. 

The optional, explicit and voluntary sending of electronic mail through the Contact Forms or by means of the addresses indicated on this Web Site involves the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other Personal Data included in the email.  

Consent to the provision of Data by the User is necessary in order to be included in the databases of the Owner and for the purposes of the establishment and proper conduct of what is offered by the same to its Users, as well as to third parties for the fulfillment of the individual activity requested. 

 Failure to provide it therefore prevents registration in the Holder’s databases, the completion of any contracts, as well as the execution of the same and any other possible activities.  

Therefore, the User’s failure to provide certain Personal Data may prevent this Website from providing its services. 

 The User assumes responsibility for the Personal Data of third parties posted or shared through this Web Site and warrants that he or she has the right to disclose or disseminate it, releasing the Owner from any liability to third parties.  

Specific summary disclosures will be progressively reported or displayed on pages of the Web Site set up for particular on-demand services. 

Communication and Dissemination of Data 

In addition to the Owner, in some cases, they may have access to the Data: 

1. categories of specially trained appointees involved in the organization of the Website (administrative, sales, marketing, legal, system administrators); 

2. 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. An up-to-date list of Data Processors, if appointed, can always be obtained from the Data Controller; 

3. Public or private entities that can access the Data in compliance with legal obligations; 

4. Individuals who perform tasks that are ancillary and instrumental to the Holder’s activity; 

5. Website Users who may view certain Data on the public profile either during the process of posting a product review; 

6. External parties such as partners in the organization of initiatives and events promoted and/or sponsored by the Data Controller to whom the communication of the Data proves necessary for organizational reasons. 

Place of Processing 

The Data are processed at the Holder’s operational headquarters. For more information you may contact the Data Controller. 

Recipients of Data and Transfer of Data Abroad 

Data may be processed by individuals and/or legal entities operating on behalf of the Data Controller and under specific contractual obligations and based in EU member countries. Personal Data will not be transferred to countries outside the EU. 

Data may be disclosed to third parties to fulfill legal obligations, to comply with orders from public authorities, or to exercise a right of the Data Controller before judicial authorities.  

Database management and processing of Data are related to the Purposes of Processing and are carried out in accordance with applicable Data Protection legislation. 

Purposes of the Processing of Collected Data 

User Data are collected to enable the Website to provide its services, as well as for the following Purposes: 

1. For purposes attributable to the legitimate interest of the Owner; 

2. To fulfill the obligations arising from the contract between the User and the Owner for the sale of packages on the Website and to provide the information requested by the User. This processing is obligatory for the performance of the contract to which the User is a party, for the execution of pre-contractual measures or to fulfill a legal obligation to which the Data Controller is subject; 

3. To fulfill any kind of obligation contemplated and provided for by current laws, regulations, related rules and business customs, in particular, in tax/fiscal matters. This processing is mandatory to fulfill a legal obligation to which the Data Controller is subject; 

4.  to follow up on specific requests made to the Controller by the User through the Website and (Contact Forms, Information Request Forms, emails) and for communications of an informational nature relating to the Controller’s own products, following the request for information via email messages or completion of the Contact Form and other communication tools.  

This processing is optional and based on the User’s consent, however, failure to provide one or more Data will result in the impossibility of responding to the request for information and enjoying the services offered by the Owner; 

5. To send promotional and commercial information and offers through the newsletter service. This processing is based on the User’s freely expressed consent; 

6. For profiling activities for marketing purposes. This Processing is based on the User’s freely expressed consent; 

7. To perform statistical analysis in pseudonymized form in order to analyze the User’s behaviors, habits and propensity to consume in order to improve the products and services provided by the Owner as well as to meet the User’s expectations. 

Nature of Data processed and consequences of refusal 

The provision of Browsing Data by Users, for the above purposes, depends on the degree of privacy you have enabled or disabled through your browser. 

 In some cases, disabling it may affect navigation on this Web Site.  

For certain modules of this Web Site, the provision of Browsing Data and/or the use of technical cookies is mandatory for the proper functioning of this Web Site. The provision of some Personal Data is in any case necessary for the very structure of the Web Site and its procedures. 

Timing of Treatment 

The Data is kept for the time necessary for the Processing of the same in relation to the performance of the service requested by the User, or required by the Purposes described in this document. 

Specifically: 

– Data collected for Purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied; 

– Data collected based on User Consent may be retained until such Consent is revoked; 

– Data collected for fiscal/administrative or contractual obligations will be retained for the time necessary to fulfill the above purposes and as required by law, for a period not exceeding that dictated by civil law and in any case for a period not exceeding 10 (ten) years; 

– Data collected for marketing and profiling purposes will be retained for a period not exceeding 24 (twenty-four) months from the acquisition of consent. 

Data may be retained by the Data Controller for a longer period in compliance with legal obligations, by order of an authority, or for legitimate interest. 

The User can always request the termination of the Processing or the deletion of the Data. 

Cookie 

This Website uses cookies. Cookies are small text files that can be used by websites to make the experience more efficient for the user and to personalize content and ads, provide social network features, and analyze traffic.  

Please refer to the more detailed Cookie Policy link: www.audaciainnovations.com/cookiepolicy  

Security measures taken 

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 the utmost security and the content of the communication is not read or manipulated in any way by third parties. 

Interaction with Social Networks 

These services enable interactions with social networks or other external platforms directly from the pages of this Website.  

Interactions and information captured by this Website are in each case subject to the User’s privacy settings 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. 

Sample types of social networks:  

(a) Facebook (Facebook Ireland Ltd.) 

Facebook buttons are interaction services with the social network Facebook, provided by Facebook Ireland Ltd.  

Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland  

(b ) Instagram (Facebook Ireland Ltd.) 

Instagram buttons are interaction services with the social network Instagram, provided by Facebook.  

Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland  

(c) Spotify  

(d ) Youtube  

(e) Tiktok 

Payment management 

Payment processing services allow this Site to process payments by credit card, wire 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 Site.  

Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding payment. 

More information about the treatment 

Upon the User’s request, in addition to the information contained in this Privacy Policy, this Web Site may provide the User with additional and contextual Informations regarding specific services, or the collection and processing of Personal Data. 

More information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact information. 

Exercise of data subject’s rights 

The Interested Party has the right to exercise the faculties provided for in Articles 7, 15-22 of Reg. European 679/2016. In particular, it has the right to: 

• Revoke their consent at any time; 
• Request access to Personal Data; 

• receive the Personal Data provided to the Data Controller and where possible transmit it to another Data Controller without hindrance (so-called portability); 
•  obtain the updating, restriction of processing, rectification of Data and deletion of Data processed in contravention of applicable regulations.  
• oppose the Processing of Personal Data concerning him/her and the Processing for the purpose of sending advertising material, direct sales and for carrying out market research; 
•  Propose complaints to the Garante della Privacy as the data protection supervisory authority.  

The data subject may exercise his or her rights by contacting the Controller by e-mail at legal@audaciainnovations.com 

Web sites or applications of third parties  

You acknowledge and agree that by using the Web Site or account you may access certain content or services provided by third parties. In that case, a different privacy policy may apply. 

The Data Controller is not responsible for the privacy policy of third parties, nor for compliance with it. 

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 the date of last modification shown at the bottom as a reference.  

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 Personal Data collected up to that point. 

Privacy Policy updated as of February 2022