Our website address is: https://simonettaroma.com (the “Site”). Simonetta Roma is a
trademark of AssuringBusiness Global SL (“AssuringBusiness”). By using this Site
or/and our services, or you interact with us via any other means, you consent to the
Processing of your Personal Data as described in this Privacy Policy. This Privacy Policy
is a part of our Terms and Conditions; by agreeing to Terms and Conditions you also
agree to this Policy. In the event of collision of terms used in Terms and Conditions and
Privacy Policy, the latter shall prevail.
We are committed to safeguarding your privacy and this Privacy Policy is provided to
help you understand how we treat your data and the obligations we commit to. You
can email our Admin team here if you have any questions or problems regarding the use
of your Personal Data and we will gladly assist.
Table of Contents
1. Definitions used in this Policy
2. Data protection principles we follow
3. What rights do you have regarding your Personal Data
4. What Personal Data we gather about you
5. How we use your Personal Data
6. How long do we keep your Personal Data
7. How can you view, edit or delete your Personal Data
8. Who else has access to your Personal Data
9. How we secure your data
10. Information about cookies
11. Contact information
Definitions
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or
on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – AssuringBusiness
Data Protection Principles
We promise to follow the following data protection principles:
Processing is lawful, fair, transparent. Our Processing activities have lawful
grounds. We always consider your rights before Processing Personal Data. We
will provide you information regarding Processing upon request.
Processing is limited to the purpose. Our Processing activities fit the purpose for
which Personal Data was gathered.
Processing is done with minimal data. We only gather and Process the minimal
amount of Personal Data required for any purpose.
Processing is limited with a time period. We will not store your personal data for
longer than needed.
We will do our best to ensure the accuracy of data.
We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s Rights
The Data Subject has the following rights:
1. Right to information – meaning you have to right to know whether your Personal
Data is being processed; what data is gathered, from where it is obtained and
why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected
from/about you. This includes your right to request and obtain a copy of your
Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or
erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your
Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have
the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to
object to Processing of your Personal Data, for example in the case of direct
marketing.
7. Right to object to automated Processing – meaning you have the right to object
to automated Processing, including profiling; and not to be subject to a decision
based solely on automated Processing. This right you can exercise whenever
there is an outcome of the profiling that produces legal effects concerning or
significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a
machine-readable format or if it is feasible, as a direct transfer from one
Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the
Rights of Access, we will provide you with a reason as to why. If you are not
satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the
help of a supervisory authority and the right for other legal remedies such as
claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for
Processing of your Personal Data.
What Personal Data we gather about you
Information you have provided us with
This might be your e-mail address, name, company name, business/home/billing
address, telephone number etc. – mainly information that is necessary for delivering
your expected level of engagement with us which may include obtaining information
about or procuring/using a product/service, subscribing you to your chosen mailing
lists, or to enhance your customer experience with us. We may also save the
information you provide us with in order for you to access member areas, comment or
perform other activities on the Site.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session
tools, for example, your IP address, your activity history on our Site (if there is any) etc.
This information is used to improve your customer experience and to enable us to
present relevant information or advertisements. Some of this information is also used
to help protect the Site and users against malicious activity. When you use our services
or look at the contents of our Site, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available.
Comments
When visitors leave comments on the Site we collect the data shown in the comments
form, and also the visitor’s IP address and browser user agent string to help spam
detection.
An anonymized string created from your email address (also called a hash) may be
provided to the Gravatar service to see if you are using it. The Gravatar service privacy
policy is available here. After approval of your comment, your profile picture is visible to
the public in the context of your comment.
Media
If you upload images to the Site, you should avoid uploading images with embedded
location data (EXIF GPS) included. Visitors to the Site can download and extract any
location data from images on the Site.
Contact Forms
We use contact forms to make it easy for you to interact with us for example by sending
enquiries, requesting information about our products and services or joining a mailing
list. Although we will necessarily store and process information from the contact form
to be able to deal with the request we will not automatically add these details to our
marketing and mailing lists, unless the contact form makes it clear that this will happen
as a result of you submitting your information and you confirm your acceptance to this.
In any event, you will always have the choice to opt-out of all marketing and mailing lists
at any time.
How we use your Personal Data
We use your Personal Data in order to:
provide our service to you. This includes for example registering your
membership/account; providing you with products and services that you have
requested; providing you with promotional items at your request and
communicating with you in relation to those products and services;
communicating and interacting with you in matters concerning your
membership/account or communications received from you; and notifying you of
changes to any content, terms and services.
enhance your customer experience;
enhance protection of the Site and our users against malicious activity;
fulfil an obligation under law or contract;
send you relevant promotional communications.
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we
Process your Personal Data for the following purposes:
to identify you;
to provide you a product/service or to send/offer you a product/service;
to communicate for sales, invoicing or other necessary product fulfilment or
service engagement.
On the grounds of legitimate interest, we Process your Personal Data for the following
purposes:
to send you personalized offers;
to administer and analyse our client and Site user base (Site and purchasing
behaviour and history) in order to improve the quality, variety, and availability of
products/ services and Site structure, function and information offered/provided;
to conduct questionnaires concerning client satisfaction or other special interest
areas.
As long as you have not informed us otherwise, we consider offering you
products/services that are similar to your purchasing history/browsing behaviour to be
our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
to send you newsletters and promotional offers;
for other purposes we have asked your consent for.
We Process your Personal Data in order to fulfil obligations arising from law and/or use
your Personal Data for options provided by law. We reserve the right to anonymise
Personal Data gathered and to use any such data. We will use data outside the scope of
this Policy only when it is anonymised.
How long do we keep your data?
We are required to save your billing information for accounting and tax purposes for six
(6) years.
If you leave a comment, the comment and its metadata are retained indefinitely. This is
so we can recognize and approve any follow-up comments automatically instead of
holding them in a moderation queue.
For users that register on our Site as members, we also store the personal information
they provide in their user profile and retain this data indefinitely until you choose to
delete that data and disable your account. All registered members can see, edit, or
delete their personal information at any time (except they cannot change their
username). Site administrators can also see and edit that information. We reserve the
right to review and disable members that have not accessed the Site membership area
for more than a year but if we do this we will notify you of our intent to do so before it
happens.
Other information gathered about you will only be maintained for a period reasonably
necessary for the obligation to service your chosen level of engagement, but not longer
than one year unless you provide permission to do so. Prior to this time limit will will
seek permission to use and store the data for a further year. If you do not give repeated
permission the data that we are not obligated by law to retain will be deleted from our
systems or anonymised.
We might process your Personal Data for additional purposes that are not mentioned
here, but are compatible with the original purpose for which the data was gathered. To
do this, we will ensure that:
the link between purposes, context and nature of Personal Data is suitable for
further Processing;
the further Processing would not harm your interests and;
there would be appropriate safeguards for Processing.
We will inform you in advance of any further Processing and purposes if and when this
should occur and give you the option to opt-out.
How you can view or delete your Personal Data
If you have an account/membership on this Site, or have left comments, you can
request to receive an exported file of the Personal Data we hold about you, including any
data you have provided to us. You can also request that we erase any Personal Data we
hold about you. This does not include any data we are obliged to keep for
administrative, legal, or security purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some
cases provided to our trusted partners in order to either make providing the service to
you possible or to enhance your customer experience. We only work with Processing
partners who are able to ensure adequate level of protection to your Personal Data. We
share your data with:
Our processing partners:
PLANETHOSTER Inc., 4416 Louis B. Mayer, Laval, Québec, Canada, H7P0G1
vbout LLC, 1412 Broadway #21st fl, New York, NY 10018, USA; vbout provides
our marketing automation platform. Their Data Processor Agreement may be
found here.
Visitor comments may be checked through an automated spam detection service.
We might disclose your Personal Data to third parties if you have consented to it or if
there are other legal grounds for it. If any portion of AssuringBusiness is sold, your
Personal Data may be part of the business assets that we transfer.
We also reserve the right to use, disclose and share your Personal Data to investigate,
prevent or take action with respect to any potential or actual crime, circumstances that
threaten the safety, rights and freedoms of any person, violations of our Terms and
Conditions or as otherwise required by law.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for
communication and transferring data (such as HTTPS). We use anonymising and
pseudonymising where suitable. We monitor our systems for possible vulnerabilities
and attacks deploying various technical and operational controls with this objective.
Even though we try our best we cannot guarantee the security of information. However,
we promise to notify suitable authorities of known data breaches. We will also notify
you if there is a threat to your rights or interests. We will do everything we reasonably
can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account/membership with us, note that you have to keep your username
and password secret and use passwords that are considered difficult to guess or hack.
Children
We do not intend to collect or knowingly collect information from children. We do not
target children with our services.
Cookies and other technologies we use
We use cookies and/or similar technologies to analyse customer behaviour, administer
the Site, track users’ movements, and to collect information about users. This is done in
order to personalise and enhance your experience with us.
You can refer to our Cookie Policy here.
Contact information
Supervisory Authority
Email: internacional@agpd.es
Phone: +34 91399 6200
AssuringBusiness
Email: email our Admin team here
Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy without notice.
Last modification was made 27 June 2024.
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