GLAM srl.’s Privacy Policy
GLAM srl collects some of its Users’ Personal Data.
Controller of the Data
GLAM srl – Via Pietro Maroncelli 2, 20154 Milano, Italy
Types of Data we collects
GLAM srl collects, either independently or by third parties, Personal Data such as: Cookies, Usage statistics, E-mail address, first and last name, phone number, street address and password.
Other types of data not mentioned above may be specified in other sections of this Privacy Policy or in other statements shown when said types are collected.
Personal Data may either be obtained directly by the user or automatically while using GLAM.
The use of Cookies – or of any other means of tracking – by GLAM or by any other third party’s services used by GLAM, is needed to identify the User and record their preferences, and is used exclusively to deliver the service the User requested.
Some services may not be available if the User chooses not to provide any of their Personal Data.
The User assumes all liability for any third party’s Personal Data they provide or share through GLAM, and ensures they have the right to communicate or spread them, freeing the Controller from any responsibility towards third parties.
Data processing modality and place
Processing mode
The Controller processes its Users’ Personal Data ensuring appropriate security measures, avoiding not authorized access, disclosure, modification or destruction of Personal Data.
The Data is processed using computer and network-based software. At times, other people, in charge of organizing the website, may be given access to the Data. These people include, but may not be limited to administrative, commercial, marketing staff; law people; system administrators; service providers, postal couriers, IT companies, communication agencies. If necessary, these people will be given by the Controller the ability to process the Data. An updated list of these people may be requested to the Controller at any time.
Place
The Data is processed at the headquarters of the Controller, and at any other place the people involved are located.
For other information, please contact the Controller.
Duration
The data is kept as long as it is needed to provide the services requested by the User, or requested for the purposes described in this document, and the User can, at any time, request the Controller to cease the Processing or to delete the Data.
Purpose of Data Collection and Processing
Users’ Data is collected so that the Controller can deliver its services, such as: Registration and authentication, Remarketing and Behavioral Targeting, Access to accounts on third parties’ services, Statistics, Contacting the Users, Advertisements, Address management and delivery of e-mails, Website hosting and back-end infrastructure, Social functionality, Payment processing, Management of support tickets, Embedding contents from external platforms, Content and functionality performance tests (A/B testing), Interaction with social networks and external platforms, platform and hosting services.
Data types used for a specific purposed are specified in other sections of this document.
Facebook permissions requested by GLAM
GLAM may request some Facebook permissions in order to perform actions with the User’s Facebook account and to collect information, including Personal Data.
For more information about the permissions, please refer to Facebook’s permission documentation and to Facebook’s privacy policy.
GLAM requests the following permissions: Contact email and Basic information.
Personal Data Collection details
Personal Data is collected for the following purposes, using the following services:
1) Access to accounts on other services’ platforms
This kind of services allow GLAM to obtain Data from Users’ accounts on third party services, and perform actions with them.
These service require the explicit authorization from the User.
Facebook account access (GLAM)
This service allows GLAM to connect to the User’s account on Facebook, provided by Facebook, Inc.
Requested permission: contact email.
Place of Data Collection: USA – Privacy Policy
Twitter account access (Twitter, Inc.)
This service allows GLAM to connect to the User’s account on Twitter, provided by Twitter, Inc.
Data collected: various types of data described in the service’s privacy policy.
Place of Data Collection: USA – Privacy Policy
2) Contact the User
Mailing List or Newsletter (BRUNO BORDESE)
When the Users registers on the mailing list or newsletter, the email address is automatically inserted in a contact list. Users in this contact list may be sent emails containing information, eventually commercial and promotional, related to GLAM. The User’s email address may also be added to some list as a result of the registration to BRUNO BORDESE, or after a purchase.
Personal Data collected: email address.
3) Social functionality
Invite and suggest friends (BRUNO BORDESE)
GLAM may use Personal Data to allow Users to invite their friends – e.g. from their phonebook, if access is given – and to suggest friends or connections.
Personal Data collected: various.
4) Payment processing
Payment management services allow GLAM to process credit card payments, bank transfers or payments made through other means. The Data is collected directly by the payment management service without being processed by GLAM.
Some of these services may also allow the User to receive scheduled messages, such as emails containing invoices or payment notifications.
PayPal (PayPal)
PayPal is a payment service offered by PayPal, Inc. It allows the User to pay on-line using their PayPal credentials.
Personal Data collected: various, as specified in PayPal’s privacy policy.
Gestpay Banca Sella (Banca Sella S.p.A.)
GestPay is a payment service offered by Banca Sella S.p.A.
Personal Data Collected: various, as specified in Banca Sella’s privacy police.
Place of processing: Italy – Privacy Policy
5) Support tickets and contact request management
Services of this type allow GLAM to manage support and contact requests received through emails or other means, such as the contact form.
Collected Personal Data depends on the information the User provides in the messages, and on the means of communication (such as email).
Freshdesk (Freshdesk, Inc.)
Freshdesk is a support ticket and contact request management service, provided by Freshdesk Inc.
Personal Data collected: various, as specified in the service’s privacy policy.
Place of data processing: USA – Privacy Policy
6) Email address management and email delivery
This kind of services allows GLAM to manage a database containing email addresses, phone numbers or any other kind of contact information, which is used to communicate with the User.
These services may also collect message viewing date and time, or other data related to the User’s interaction with them, such as link click info on links inside of the message.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message delivery service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
Place of data processing: USA – Privacy Policy
SendInBlue (Sendinblue SAS)
SendInBlue is an email address management and message delivery service.
Personal data collected: email address, first and last name, country, EU tax ID, street address, phone number, IP address(es) and domain name, access data, browsing data (if given access), order history, complaints.
Place of data processing: France – Privacy Policy
7) Web hosting and back-end infrastructure
This type of services’ purpose is to host data and files required for GLAM’s functioning. They allow its distribution and provide a ready-to-use infrastructure that provides GLAM’s services.
These services are hosted on servers located in different countries, making it difficult to determine where exactly Personal Data is kept.
1&1 (Web Services 1&1)
1&1 Web Services is a hosting provider offered by 1and1.com Internet, Inc.
Personal Data collected: various, as described in the service’s privacy policy.
8) Social network interaction and external platforms
This type of services allow the user to interact on GLAM’s website with social networks or with other external platforms.
Information collected by GLAM is subject to User’s settings on each social network and platform.
If a social network interaction service is installed, it is possible that, even if the User doesn’t actually use the service, some traffic data may be collected on pages in which it is installed.
PayPal widget and button (PayPal)
PayPal widgets and buttons are services provided by PayPal Inc. that allow to interact with their platform.
Personal data collected: cookies and usage data.
Place of collection: refer to PayPal’s - Privacy Policy
9) Advertisements
This kind of services use the User’s Data for commercial communication purposes in different forms of advertisements, such as banners, even relatively to the User’s interests.
However, this doesn’t mean that all collected Personal Data will be used for this purpose. Data and usage terms are described later in this document.
Some of the following services may use Cookies to identify the User, or for Behavioral Retargeting, which consists in viewing advertisements based on interests and behavior of the User. This information may be collected outside of GLAM’s website.
For more information, please refer to the privacy policies of each service.
Direct Email Marketing (DEM) (BRUNO BORDESE)
GLAM uses User’s Data to send commercial suggestions concerning products and services provided by third parties, or not otherwise related to GLAM’s services and products.
Personal Data collected: email address.
SendInBlue (Sendinblue SAS)
SendInBlue is an email address management and message delivery service.
Personal data collected: email address, first and last name, country, EU tax ID, street address, phone number, IP address(es) and domain name, access data, browsing data (if given access), bank account details (if given access), order history, complaints.
Place of data processing: France – Privacy Policy
10) Registration and authentication
By registering or authenticating themselves on the platform, the User allows the Application to identify them and to give them access to dedicated services.
Authentication services may be provided by third parties. If this is the case, the Application may be able to access and collect some data provided by the third party authentication service.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and connected to Facebook social network.
Personal data collected: various, as described in the service’s privacy policy.
Place of data processing: USA – Privacy Policy
Twitter OAuth (Twitter, Inc.)
Twitter OAuth is a registration and authentication service provided by Twitter, Inc. and connected to Twitter social network.
Personal data collected: various, as described in the service’s privacy policy.
Place of data processing: USA – Privacy Policy
Google OAuth (Google Inc.)
Google OAuth is a registration and authentication service provided by Google, Inc. and connected to Google’s network.
Personal data collected: various, as described in the service’s privacy policy.
Place of data processing: USA – Privacy Policy
Direct registration (BRUNO BORDESE)
The user registers on the registration form, providing their Personal Data to BRUNO BORDESE.
Personal data collected: first and last name, email address, street address, phone number, password.
Log In with PayPal (PayPal)
Log In with PayPal is a registration and authentication service provided by PayPal Inc. and connected to PayPal’s network.
Personal data collected: various, as described in the service’s privacy policy.
Place of data collection: refer to PayPal’s privacy policy – Privacy Policy
11) Remarketing and Behavioral Targeting
This kind of services allows GLAM and their partners to communicate, to optimize and serve advertisements based on past usage by the User of BRUNO BORDESE.
This is achieved by tracking usage data using Cookies; this information is transferred to the partner which provide remarketing and behavioral targeting services.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a Remarketing and Behavioral Targeting service that connects GLAM’s activity with Facebook’s advertising network. It is provided by Facebook, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
Remarketing with Google Analytics for advertisements (Google, Inc.)
Google Analytics for advertisements is a Remarketing and Behavioral Targeting service that connects Google Analytics’ tracking activity with Adwords and DoubleClick. It is provided by Google, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a Remarketing and Behavioral Targeting service that connects GLAM’s activity with AdWords and DoubleClick advertising networks. It is provided by Google, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a Remarketing and Behavioral Targeting service that connects GLAM’s activity with Facebook’s advertising network. It is provided by Facebook, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
Twitter Remarketing (Twitter, Inc.)
Twitter Remarketing is a Remarketing and Behavioral Targeting service that connects GLAM’s activity with Twitter’s advertising network. It is provided by Twitter, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
Twitter Tailored Audiences (Twitter, Inc.)
Twitter Tailored Audiences is a Remarketing and Behavioral Targeting service that connects GLAM’s activity with Twitter’s advertising network. It is provided by Twitter, Inc.
Personal Data collected: cookies and usage data.
Place of data collection: USA – Privacy Policy – Opt Out
12) Web hosting and platform services
GLAM uses these services in order to host key components of GLAM, making it possible to provide it from a single platform. These platforms give the Controller a wide range of tools such as data analysis tools, tools to manage user registration, comments, database, e-commerce, payments, etc. The use of these tools involves the collection and processing of Personal Data. Some of these services are hosted on servers located in different places, making it difficult to determine where exactly Personal Data is kept.
PrestaShop (PrestaShop S.A.)
PrestaShop is a platform that allows the Controller to develop and host a website dedicated to electronic commerce. It is provided by PrestaShop S.A.
Personal data collected: various, as described in the service’s privacy policy.
Place of data collection: France – Privacy Policy
13) Statistics
The following services allow the Controller to monitor and analyze traffic data and User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service offered by Google Inc. (“Google”). Google uses collected Personal Data to track and examine GLAM’s usage, build reports and improve other services from Google.
Google may use Personal Data to contextualize and customize advertisements on its advertising network.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy – Opt Out
Google AdWords Conversion Tracking (Google Inc.)
Google AdWords Conversion Tracking is a statistics service that connects data from Google AdWords’ advertisement network with actions performed inside of GLAM.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
Facebook Ads Conversion Tracking (Facebook, Inc.)
Facebook Ads Conversion Tracking is a statistics service that connects data from Facebook’s advertisement network with actions performed inside of GLAM.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
Google Tag Manager (Google Inc.)
Google Tag Manager is a statistics service provided by Google Inc.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
Twitter Ads Conversion Tracking (Twitter, Inc.)
Twitter Ads Conversion Tracking is a statistics service that connects data from Twitter’s advertisement network with actions performed inside of GLAM.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
Google Analytics User ID Extension (Google, Inc.)
Google Analytics uses on GLAM a function called User ID. This function allows for a more accurate User tracking, by assigning a unique ID for different sessions on different devices, in a way that doesn’t allow Google to identify in a personal manner a person or a device permanently.
User ID Extension also allows to connect data from Google Analytics with other user related data collected by GLAM.
The opt-out link below allows the User to disable tracking on the device in use, but does not exclude other tracking activities from the Controller. To opt out from the latter, please contact the Controller using the contact email address.
Personal Data collected: cookies.
Place of Data collection: USA – Privacy Policy – Opt Out
14) Content and functionality performance tests (A/B testing)
The following services enable the Controller to keep track of and analyze the User response after the modification of GLAM’s structure, texts or any other component.
Google Website Optimizer (Google Inc.)
Google Website Optimizer is an A/B testing service provided by Google Inc. (“Google”).
Google may use Personal Data to contextualize and customize advertisements on his advertising network.
Personal Data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
15) Embedding content from external platforms
This kind of services allow GLAM to embed content in its website that is hosted on other platforms. If a service of this kind is installed in a page, it may be possible that, even if it is not interacted with by the user, it may collect traffic data of these pages.
Google Fonts (Google Inc.)
Google Fonts is a typeface hosting platform managed by Google Inc. It allows GLAM to integrate content in its website.
Personal data collected: various, as described in the service’s privacy policy.
Place of Data collection: USA – Privacy Policy
Google Maps Widget (Google Inc.)
Google Maps is a map service managed by Google Inc. It allows GLAM to integrate content in its website.
Personal data collected: cookies and usage data.
Place of Data collection: USA – Privacy Policy
Vimeo Videos (Vimeo, LLC)
Vimeo is a video hosting platform managed by Vimeo, LLC It allows GLAM to integrate content in its website.
Personal data collected: various, as described in the service’s privacy policy.
Place of Data collection: USA – Privacy Policy
Other information on Personal Data
Sale of goods and on-line services
Collected Personal Data is used to deliver services to the User or to sell products, including payment and delivery.
To perfection payments, Personal Data may be collected such as credit card number, bank account number and other related information. Personal Data collected by GLAM depends on the payment system used.
Cookie Policy
GLAM uses Cookies.
Other information on data processing
Defense in court
User Personal Data may be used by the Controller in court or to report and defend from abuses in GLAM’s or its connected services’ usage.
The user is aware that government authorities may request Personal Data to the Controller.
Specific information
In addition to the information in this privacy policy, if the User requests it, GLAM may provide the User with additional information about specific services, or about Personal Data collection and processing.
System logs and maintenance
GLAM and other third services it uses may collect system logs. System logs are files that record, among other things, User interactions, and may contain Personal Data such as IP addresses. The logs are needed for system maintenance and administration.
Information not in this policy
Further information about how Personal Data is collected and processed can be requested at any time to the Controller using contact information.
Exercise of rights by Users
People to which Personal Data refer to have the right, at any time, to know from the Controller whether said data exists, its origin and content, its deletion or update, its transformation into an anonymous form, or to stop collection of Personal Data processed in a way that is against the law. They can also appeal, for legitimate reasons, to its collection. Such requests must be sent to the Controller.
GLAM does not support “Do Not Track” headers.
To find out if third party services used by GLAM support them, please refer to their privacy policy.
Changes to this policy
The Controller reserves the right to modify this document at any time, publishing changes on this page. For this reason, it is advised to check it often. Please check the modification date on the bottom of this page.
If the User does not agree with modifications of this policy, they should stop using GLAM and may request the Controller to delete their own Personal Data. Unless otherwise stated, this privacy policy will continue to apply to Data collected upon that moment.
Information on this privacy policy
The Controller of the Data is responsible for this privacy policy.
Definitions and legal references
Personal Data (or Data)
Any information referred to a physical person, either identified or identifiable, even indirectly by means of any other information, including a personal ID, is considered personal data.
Usage Data
Information collected automatically by GLAM or by third party applications GLAM uses, such as: IP address of the devices used to connect with GLAM, URI (Uniform Resource Identifier) addresses, request times, request methods, response file size, HTTP response code, country, browser and operating system characteristics, time of stay on a page, path followed inside of the Application, especially the sequence of page visited, parameters referred to the operating system of the User.
User
The person who uses GLAM, who must be the same as the Person Concerned or be authorized, whose Personal Data are subject to collection.
Person Concerned
The physical or legal person to whom Personal Data refers to.
Responsible of the Data (or Responsible)
The physical or legal person, the public administration or any other body put by the Controller in charge of Data collection or processing, according to what is stated in this privacy policy.
Controller of the Data (or Controller)
The physical or legal person, the public administration who are in charge, even together with other controllers, of the decisions about the finality, the way the data will be processed and the tools used to process it, including the security profile, in relation to how GLAM works and how GLAM uses the data. The Controller, unless otherwise stated, is GLAM’s owner.
GLAM
The hardware or software using which Personal Data is collected.
Cookie
Small piece of data kept in the User’s device.
Legal references
To European users: this policy has been written according to obligations under Art. 10 of Directive n. 95/46/CE and n. 2009/136/CE, regarding Cookies.
This policy regards GLAM only.