PRIVACY POLICY

Privacy Policy Statement 

Our postal address is 

510 Briscoe Blvd. Suite 200 

Briscoe Field / Gwinnett County Airport 

Lawrenceville, GA 30046 

We can be reached via e-mail at charter@charterjetsinc.com or you can reach us by telephone at +1 678 385 4002 Please, read also our Cookie Policy statement. 

PRIVACY POLICY OF CHARTERJETSINC.COM 

This Website collects some Personal Data from its Users. 

This document contains a section dedicated to California consumers and their privacy rights. 

This document contains a section dedicated to Virginia consumers and their privacy rights. 

This document can be printed for reference by using the print command in the settings of any browser. 

OWNER AND DATA CONTROLLER 

Charter Jets, Inc. 510 Briscoe Blvd. Suite 200, Lawrenceville, GA 30046 

Owner contact email: charter@charterjetsinc.com 

TYPES OF DATA COLLECTED 

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; company name; email address; ZIP/Postal code; field of activity; various types of Data; geographic position; Data communicated in order to use the Service; Data communicated while using the service; session duration; scroll-to-page interactions; clicks; time zone; device information; custom events; number of Users; city; session statistics; latitude (of city); longitude (of city). Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.


Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.


Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.


Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner. 

MODE AND PLACE OF PROCESSING THE DATA 

METHODS OF PROCESSING 

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.


The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time. 

LEGAL BASIS OF PROCESSING 

The Owner may process Personal Data relating to Users if one of the following applies: 

▪ Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; 

▪ provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; 

▪ processing is necessary for compliance with a legal obligation to which the Owner is subject; 

▪ processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; 

▪ processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. 

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

PLACE 

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.


Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. 

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.


If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the 

information provided in the contact section. 

RETENTION TIME 

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. 

Therefore: 

▪ Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. 

▪ Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. 

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.


Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data 

portability cannot be enforced after expiration of the retention period. 

THE PURPOSES OF PROCESSING 

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, Data transfer outside the EU, Traffic optimization and distribution, Displaying content from external platforms, Heat mapping and session recording, Remarketing and behavioral targeting, SPAM protection, RSS feed management, Managing support and contact requests, Location-based interactions, Tag Management, Interaction with live chat platforms, Hosting and backend infrastructure, Content performance and features testing (A/B testing) and Interaction with support and feedback platforms. 

For specific information about the Personal Data used for each purpose, the 

User may refer to the section “Detailed information on the processing of Personal Data”. 

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA 

Personal Data is collected for the following purposes and using the following services: 

• ANALYTICS

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
GOOGLE ANALYTICS (GOOGLE INC.)


Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. 

• Google may use the Data collected to contextualize and personalize the ads of its own advertising network.


Personal Data processed: Cookies; Usage Data.


Place of processing: US – Privacy Policy – Opt Out.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• GOOGLE ADS CONVERSION TRACKING (GOOGLE LLC)

Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA  

• GOOGLE ANALYTICS 4

Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. 

• Google may use the Data collected to contextualize and personalize the ads of its own advertising network. 
• In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.


Personal Data processed: city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage 

Data.


Place of processing: United States – Privacy Policy – Opt Out; Ireland –

 Privacy Policy – Opt Out.


Category of personal information collected according to the CCPA: 

identifiers; internet information; geolocation data.


This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• CONTACTING THE USERCONTACT FORM (THIS WEBSITE)

By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.


Personal Data processed: company name; email address; field of activity; first name; last name; phone number; ZIP/Postal code.


Category of personal information collected according to the CCPA: 

identifiers; commercial information; internet information.


This processing constitutes: 

▪ a sale according to the VCDPA 

• MAILING LIST OR NEWSLETTER (THIS WEBSITE)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.Personal Data processed: email address; first name; last name.Category of personal information collected according to the CCPA: identifiers.

This processing constitutes: 

▪ a sale according to the VCDPA 

• PHONE CONTACT (THIS WEBSITE)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.


Personal Data processed: phone number.


Category of personal information collected according to the CCPA: identifiers.


This processing constitutes: 

▪ a sale according to the VCDPA 

• CONTENT PERFORMANCE AND FEATURES TESTING (A/B TESTING)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.


GOOGLE OPTIMIZE

Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google may use Personal Data to contextualize 

and personalize the ads of its own advertising network.


Personal Data processed: Tracker; Usage Data.


Place of processing: United States – Privacy Policy; Ireland – Privacy 

Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• DATA TRANSFER OUTSIDE THE EU

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.


Users can inquire with the Owner to learn which legal basis applies to which specific service.


DATA TRANSFER ABROAD BASED ON CONSENT (THIS WEBSITE)

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. 

• In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Website.


Personal Data processed: various types of Data.


Category of personal information collected according to the CCPA: 

internet information.


DATA TRANSFER ABROAD BASED ON STANDARD CONTRACTUAL CLAUSES (THIS WEBSITE)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission. 

• This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.


Personal Data processed: various types of Data.


Category of personal information collected according to the CCPA: 

internet information.


DATA TRANSFER FROM THE EU AND/OR SWITZERLAND TO THE U.S BASED ON PRIVACY SHIELD (THIS WEBSITE)

If this is the legal basis, the transfer of Personal Data from the EU or 

Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield. 

• In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce. 
• Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.


Personal Data processed: various types of Data.


Category of personal information collected according to the CCPA: internet information.


DATA TRANSFER TO COUNTRIES THAT GUARANTEE EUROPEAN STANDARDS (THIS WEBSITE)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission. 

• The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.


Personal Data processed: various types of Data.


Category of personal information collected according to the CCPA: internet information.


OTHER LEGAL BASIS FOR DATA TRANSFER ABROAD (THIS WEBSITE)

If no other legal basis applies, Personal Data shall be transferred from the 

EU to third countries only if at least one of the following conditions is met: 

▪ the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request; 

▪ the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person; 

▪ the transfer is necessary for important reasons of public interest; 

▪ the transfer is necessary for establishment, exercise or defence of legal claims; 

▪ the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Website. 

Personal Data processed: various types of Data.


Category of personal information collected according to the CCPA: 

internet information.

• DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.


GOOGLE MAPS WIDGET (GOOGLE INC.)

Google Maps is a maps visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA • GOOGLE FONTS (GOOGLE INC.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA • YOUTUBE VIDEO WIDGET (GOOGLE INC.)

YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• YOUTUBE IFRAME PLAYER

YouTube IFrame Player is a video content visualization service provided by 

Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages. Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document. Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising 

Initiative opt-out page.


Personal Data processed: Data communicated in order to use the Service.


Place of processing: United States – Privacy Policy – Opt out; Ireland –

 Privacy Policy – Opt out.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA  

• HEAT MAPPING AND SESSION RECORDING

Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.


Some of these services may record sessions and make them available for later visual playback.


INSPECTLET (INSPECTLET INC.)

Inspectlet is a session recording and heat mapping service provided by 

Inspectlet Inc.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• MICROSOFT CLARITY (MICROSOFT CORPORATION)

Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation. 

• Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft 

Privacy Statement, including improving and providing Microsoft 

Advertising.


Personal Data processed: clicks; custom events; device information; scroll-to-page interactions; session duration; time zone; Trackers; Usage 

Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• HOSTING AND BACKEND INFRASTRUCTURE

This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the 

actual location where the Personal Data are stored.


IUBENDA CONSENT SOLUTION (IUBENDA SRL)

iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.


Personal Data processed: Data communicated while using the service.


Place of processing: Italy – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.

• INTERACTION WITH LIVE CHAT PLATFORMS

This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.


If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

ZENDESK CHAT (ZENDESK, INC.)

Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.


Personal Data processed: email address; first name; last name.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: identifiers.


This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• INTERACTION WITH SUPPORT AND FEEDBACK PLATFORMS

This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Website.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.


ZENDESK WIDGET (ZENDESK, INC.)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.


Personal Data processed: email address; first name; last name; phone number.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: identifiers.


This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

• LOCATION-BASED INTERACTIONS


GEOLOCATION (THIS WEBSITE)

This Website may collect, use, and share User location Data in order to provide location-based services. 

• Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.


Personal Data processed: geographic position.


Category of personal information collected according to the CCPA: geolocation data.


This processing constitutes: 

▪ a sale according to the VCDPA  

▪ a sharing according to the CCPA 

▪ targeted advertising according to the VCDPA 

• MANAGING SUPPORT AND CONTACT REQUESTS

This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).


ZENDESK (ZENDESK, INC.)

Zendesk is a support and contact request management service provided by Zendesk Inc.


Personal Data processed: various types of Data as specified in the privacy policy of the service.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA  

• REMARKETING AND BEHAVIORAL TARGETING

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the 

User.


This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.


Some services offer a remarketing option based on email address lists.


In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.


Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.


REMARKETING WITH GOOGLE ANALYTICS (GOOGLE LLC)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google 

Ads advertising network and the Doubleclick Cookie.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

▪ a sharing according to the CCPA 

▪ targeted advertising according to the VCDPA 

• FACEBOOK REMARKETING (FACEBOOK, INC.)


Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

▪ a sharing according to the CCPA 

▪ targeted advertising according to the VCDPA 

• GOOGLE AD MANAGER AUDIENCE EXTENSION (GOOGLE LLC)


Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

▪ a sharing according to the CCPA  

▪ targeted advertising according to the VCDPA 

• GOOGLE ADS REMARKETING (GOOGLE LLC)


Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google’s use of cookies for ads personalization by visiting 

Google’s Ads Settings.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

▪ a sharing according to the CCPA 

▪ targeted advertising according to the VCDPA 

• RSS FEED MANAGEMENT

This type of service allows this Website to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.


FEEDBURNER (GOOGLE INC.)


Feedburner is a service to manage RSS feeds provided by Google Inc. It allows the collection of statistics on what content is consumed and to insert ads in it.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA 

• SPAM PROTECTION

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts 

of traffic, messages and content that are recognized as SPAM.


GOOGLE RECAPTCHA (GOOGLE INC.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc. 

• The use of reCAPTCHA is subject to the Google privacy policy and terms of use.


Personal Data processed: Cookies; Usage Data.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.

• TAG MANAGEMENT

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.


This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.


GOOGLE TAG MANAGER

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.


Personal Data processed: Usage Data.


Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA 

• TRAFFIC OPTIMIZATION AND DISTRIBUTION

This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.


Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal 

Information of the User are transferred.


CLOUDFLARE (CLOUDFLARE INC.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. 

• The way Cloud flare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User’s browser, while also allowing analytical data from this Website to be collected.


Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.


Place of processing: United States – Privacy Policy.


Category of personal information collected according to the CCPA: 

internet information.
This processing constitutes: 

▪ a sale according to the CCPA and the VCDPA 

INFORMATION ON OPTING OUT OF INTEREST-BASED ADVERTISING 

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy. 

FURTHER INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA 

• PERSONAL DATA COLLECTED THROUGH SOURCES OTHER THAN THE 

USER

The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing. 

• Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

• IUBENDA COOKIE SOLUTION (CONSENT COOKIE)

iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers in the local domain.

• IUBENDA COOKIE SOLUTION (REMOTE CONSENT COOKIE)


Remote iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie 

Solution and stores User preferences related to Trackers under the .iubenda.com domain.

• IUBENDA CONSENT SOLUTION LOCALSTORAGE


iubenda ConS JS library localStorage (IUB_DATA) temporarily stores pending data in a storage space internal to the User’s browser (localStorage) until it’s received by the API, then it is deleted.

• IUBENDA CCPA COOKIE (USPRIVACY)


iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain.

THE RIGHTS OF USERS 

Users may exercise certain rights regarding their Data processed by the Owner. 

In particular, Users have the right to do the following: 

▪ Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. 

▪ Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. 

▪ Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. 

▪ Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. 

▪ Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. 

▪ Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. 

▪ Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof. 

▪ Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. 

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING 

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

HOW TO EXERCISE THESE RIGHTS 

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month. 

COOKIE POLICY 

This Website uses Trackers. To learn more, the User may consult the Cookie Policy. 

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING 

LEGAL ACTION 

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this 

Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities. 

ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA 

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. 

SYSTEM LOGS AND MAINTENANCE 

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) 

or use other Personal Data (such as the IP Address) for this purpose. 

INFORMATION NOT CONTAINED IN THIS POLICY 

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document. 

HOW “DO NOT TRACK” REQUESTS ARE HANDLED 

This Website does not support “Do Not Track” requests.


To determine whether any of the third-party services it uses honor the “Do Not 

Track” requests, please read their privacy policies. 

CHANGES TO THIS PRIVACY POLICY 

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required. 

INFORMATION FOR CALIFORNIAN CONSUMERS 

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). 

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the “California Consumer Privacy Act of 2018” (the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. 

This part of the document uses the term “personal information“ as defined in the 

California Consumer Privacy Act (CCPA/CPRA). 

NOTICE AT COLLECTION 

CATEGORIES OF PERSONAL INFORMATION COLLECTED, USED, SOLD, OR SHARED 

In this section we summarize the categories of personal information that we’ve collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the 

processing of Personal Data” within this document. 

INFORMATION WE COLLECT: THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT 

We have collected the following categories of personal information about you: identifiers, commercial information, internet information and geolocation data. 

We do not collect sensitive personal information. 

We will not collect additional categories of personal information without notifying you. 

WHAT ARE THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION? 

We may use your personal information to allow the operational functioning of this Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. 

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent. 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? 

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for. 

HOW WE COLLECT INFORMATION: WHAT ARE THE SOURCES OF THE PERSONAL INFORMATION WE COLLECT? 

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Website. 

For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, as personal information about you is automatically observed and collected. 

Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof. 

HOW WE USE THE INFORMATION WE COLLECT: DISCLOSING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR A BUSINESS PURPOSE 

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA. We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in 

accordance with the different purposes of processing. 

SALE OR SHARING OF YOUR PERSONAL INFORMATION 

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA. 

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like. 

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.


Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information. 

YOUR RIGHT TO OPT OUT OF THE SALE OR SHARING OF YOUR 

PERSONAL INFORMATION AND HOW YOU CAN EXERCISE IT 

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal 

Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.


Such requests can be made freely, at any time, without submitting any verifiable request.


To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.


For a simplified opt-out method you can also use the privacy choices link provided on this Website. 

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here. 

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. 

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind. 

YOUR PRIVACY RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT 

AND HOW TO EXERCISE THEM 

THE RIGHT TO ACCESS PERSONAL INFORMATION: THE RIGHT TO KNOW AND TO PORTABILITY 

You have the right to request that we disclose to you: 

▪ the categories of personal information that we collect about you; 

▪ the sources from which the personal information is collected; 

▪ the purposes for which we use your information; 

▪ to whom we disclose such information; 

▪ the specific pieces of personal information we have collected about you. 

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose: 

▪ the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared; 

▪ the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. 

The disclosure described above will be limited to the personal information collected or used over the past 12 months. 

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible. 

THE RIGHT TO REQUEST THE DELETION OF YOUR PERSONAL INFORMATION 

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). 

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort. 

THE RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION 

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. 

THE RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION AND TO LIMIT THE USE OF YOUR SENSITIVE PERSONAL INFORMATION 

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information. 

THE RIGHT OF NO RETALIATION FOLLOWING OPT-OUT OR EXERCISE OF OTHER RIGHTS (THE RIGHT TO NON-DISCRIMINATION) 

We will not discriminate against you for exercising your rights under the CCPA. 

This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights. 

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. 

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information. 

HOW TO EXERCISE YOUR RIGHTS 

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must: 

▪ provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; 

▪ describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. 

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. 

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. 

You can submit a maximum number of 2 requests over a period of 12 months. 

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST 

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. 

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. 

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort. 

Should we deny your request, we will explain you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it. 

INFORMATION FOR VIRGINIA CONSUMERS 

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, 

“our”). 

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal data” as defined in the 

VCDPA. 

CATEGORIES OF PERSONAL DATA PROCESSED 

In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of 

Persona Data” within this document. 

CATEGORIES OF PERSONAL DATA WE COLLECT 

We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data and employment related information 

We do not collect sensitive data. 

We will not collect additional categories of personal data without notifying you. 

WHY WE PROCESS YOUR PERSONAL DATA 

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document. 

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document. 

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES 

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.


For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an 

affiliate of the processor or the controller” as defined by the VCDPA. 

SALE OF YOUR PERSONAL DATA 

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.


As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA. 

YOUR RIGHT TO OPT OUT OF THE SALE OF YOUR PERSONAL DATA AND HOW YOU CAN EXERCISE IT 

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document. 

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request. 

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING 

For our purposes, the word “targeted advertising” means “displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests” as defined by the 

VCDPA. 

To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document. 

YOUR RIGHT TO OPT OUT OF THE PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING AND HOW YOU CAN EXERCISE IT 

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your 

right to opt out you can contact us at any time, using the contact details provided in this document. 

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. 

YOUR PRIVACY RIGHTS UNDER THE VIRGINIA CONSUMER DATA 

PROTECTION ACT AND HOW TO EXERCISE THEM 

You may exercise certain rights regarding your data processed by us. In 

particular, you have the right to do the following: 

▪ access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data. 

▪ correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data. 

▪ request the deletion of your personal data. You have the right to request that we delete any of your personal data. 

▪ obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible. 

▪ opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. 

▪ non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program. 

HOW TO EXERCISE YOUR RIGHTS 

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. For us to respond to your request, we need to know who you are. 

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. 

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes. 

If you are an adult, you can make a request on behalf of a minor under your parental authority. 

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST 

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. 

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint. 

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them. DEFINITIONS AND LEGAL REFERENCES 

PERSONAL DATA (OR DATA) 

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. 

USAGE DATA 

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment. 

USER 

The individual using this Website who, unless otherwise specified, coincides with the Data Subject. 

DATA SUBJECT 

The natural person to whom the Personal Data refers. 

DATA PROCESSOR (OR DATA SUPERVISOR) 

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy. 

DATA CONTROLLER (OR OWNER) 

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the 

Owner of this Website. 

THIS WEBSITE (OR THIS APPLICATION) 

The means by which the Personal Data of the User is collected and processed. SERVICE 

The service provided by this Website as described in the relative terms (if available) and on this site/application. 

EUROPEAN UNION (OR EU) 

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area. 

COOKIE 

Cookies are Trackers consisting of small sets of data stored in the User’s browser. 

TRACKER 

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device. 

LEGAL INFORMATION 

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). 

This privacy policy relates solely to this Website, if not stated otherwise within this document. 

Latest update: March 27, 2023 

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. 

For each visitor to our web page, our web server does not recognize information regarding the domain or e-mail address. 

We collect the e-mail addresses of those who communicate with us via e-mail, information volunteered by the consumer, such as survey information and/or site registrations, telephone number, fax number. 

The information we collect is used to contact consumers in response to private jet charter flight inquiries. Consumers’ contact information will not be sold or divulged to any third party individuals or organizations. 

With respect to cookies: We use cookies to store visitors preferences. 

If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the above address. 

Persons who supply us with their telephone numbers on-line will only receive telephone contact from us with information regarding private jet charter inquiries they have placed on-line. 

Please provide us with your name and phone number, so we can give you accurate quotes and further information regarding our charter services. 

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice such as a newsletter or charter services that match your flight preferences. If our information practices change at some time in the future we will contact you before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses. 

Customers may prevent their information from being used for purposes other than those for which it was originally collected by emailing us at the above address. 

Upon request we provide site visitors with access to all information [including proprietary information] that we maintain about them, transaction information (e.g., dates on which customers chartered flights, flight itineraries) that we maintain about them, communications that the consumer/visitor has directed to our site (e.g., e-mails, customer inquiries), contact information (e.g., name, address, phone number) that we maintain about them . 

Consumers can access this information by e-mailing us at the above address. 

Upon request we offer visitors the ability to have inaccuracies corrected in contact information, transaction information. 

Consumers can have this information corrected by sending us email at the above address. 

If you feel that this site is not following its stated information policy, you may contact us at the above addresses or phone number.