Privacy Policy of elmastransfer.com

This Website collects some Personal Data of its Users. This document can be printed using the print command in the settings of any browser.

Data Controller

The data controller is Blue Transfer s.r.l. Via Turbigo 5, 09123 Cagliari, p.i./c.f 03763670928, contact email: info@elmastransfer.com

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: Usage Data; Tools of Tracking; name; surname; email; billing address; purchase history. Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the collection of the data. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website. Unless otherwise specified, all Data required by this Website is mandatory. If you refuse to provide them, it may be impossible for this Website to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequences on the availability of the Service or its operation. Users who have doubts about which Data is mandatory, are encouraged to contact the Owner.

The possible use of Cookies - or other tracking tools - by this Website or by the owners of third party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, freeing the Controller from any liability to third parties.

Method and place of processing of the collected Data

Method of treatment

The Data Controller shall take appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out by means of computer and/ or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects may have access to the Data (as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller. The updated list of Data Processors may always be requested from the Data Controller.

Legal basis of processing

The Data Controller processes Personal Data relating to the User if one of the following conditions is met:

the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorised to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;

the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
the processing is necessary to fulfil a legal obligation to which the Data Controller is subject;

the processing is necessary for the performance of a task in the public interest or for the exercise of public authority by the Data Controller;
the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

however it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided by a contract or necessary to conclude a contract.

Place

The Data are processed at the operating offices of the Data Controller and at any other place where the parties involved in the processing are located. For further information, contact the Data Controller.

Your Personal Data may be transferred to a country other than the country where you are located. For further information on the place of processing, the User can refer to the section on the details of the processing of Personal Data.

The User has the right to obtain information about the legal basis of the transfer of Data outside the European Union or to an international public law organization or constituted by two or more countries, such as the UN, as well as the security measures taken by the Data Controller to protect the Data.

The User can verify if one of the transfers described above takes place by examining the section of this document relating to the details of the processing of Personal Data or asking the Data Controller for information by contacting him at the contact details shown at the opening.

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• The Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of this contract is completed.
• The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. In addition, the Data Controller may be obliged to store Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the Processing of Collected Data

• The User’s Data are collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforceable actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Viewing content from external platforms, Statistics and Payment Management.
• To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the section "Details on the processing of Personal Data".

Details on the processing of Personal Data

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

Payment management

Unless otherwise specified, this Website processes all payments by credit card, bank transfer or other means through external payment service providers. In general, and unless otherwise indicated, Users are requested to provide payment details and personal information directly to such payment service providers.

This Website is not involved in the collection and processing of such information; instead, it will only receive a notification from the payment service provider concerned that payment has been made.

Stripe ( Stripe Technology Europe Ltd)

Stripe is a payment service provided by Stripe Technology Europe Ltd.

Personal Data processed: surname; purchase history; Data of use; email; billing address; name; Tools of Tracking; various types of Data as specified by the privacy policy of the service.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the ACFA: identifiers; commercial information; information on the Internet.

• Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the collected Personal Data for the purpose of tracking and reviewing the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads

of its advertising network.

Personal Data processed: Usage Data; Tools of Tracking.

Place of processing: Ireland - Privacy Policy - Opt Out.

Category of personal information collected under the ACFA: information on the Internet.

This type of treatment constitutes:

a sale pursuant to ACFA and VCDPA

Google Ads Conversion Tracking (Google Ireland Limited)

Google Ads Conversion Tracking is a statistics service provided by Google Ireland Limited that links data from the Google Ads ad network with actions taken within this Website.

Personal Data processed: Usage Data; Tools of Tracking.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the ACFA: information on the Internet.

This type of treatment constitutes:

a sale pursuant to ACFA and VCDPA

Viewing 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 to interact with them.

This type of service may still collect data on web traffic related to pages where the service is installed, even when users do not use it.

Font Awesome (Fonticons, Inc. )

Font Awesome is a font style display service operated by Fonticons, Inc.

which allows this Website to integrate such content within its own pages.

Personal Data processed: Usage Data; Tools of Tracking.

Place of processing: United States - Privacy Policy.

Category of personal information collected under the ACFA: information on the Internet.

This type of treatment constitutes:

a sale pursuant to ACFA and VCDPA

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Website to integrate such content within its pages.

Personal Data processed: Usage Data; Tools of Tracking.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the ACFA: information on the Internet.

This type of treatment constitutes:

• a sale pursuant to ACFA and VCDPA
   

User rights

Users can exercise certain rights with regard to the Data processed by the Data Controller.

In particular, the User has the right to:

• revoke your consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.
• oppose the processing of your Data. The User may object to the processing of his Data when it takes place on a legal basis other than consent. Further details on the right to object are given in the section below.
• access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the correctness of their Data and request its update or correction.
• obtain the restriction of processing. When certain conditions are met, the User may request the limitation of the processing of his Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
• obtain the deletion or removal of your Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive your Data or have it transferred to another data controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another holder. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
• complain. You may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public authority referred to in

invested the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise the rights

To exercise the User’s rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

 

Cookie Policy

This Website makes use of Tracking Tools. To learn more, the User can consult the Cookie Policy.

Further information on the processing

Arraignment

The User’s Personal Data may be used by the Data Controller in court or in the preparatory phases to its possible establishment for the defense against abuse in the use of this Website or the Services connected by the User.

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information

At your request, in addition to the information contained in this privacy policy, this Website may provide you with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

Log of system and maintenance

Due to operational and maintenance requirements, this Website and any third party services used by it may collect system logs, ie files that record interactions and may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information regarding the processing of Personal Data may be requested at any time to the Data Controller using the contact details.

Response to "Do Not Track" requests

This Website does not support "Do Not Track" requests.

To find out if any third party services used support them, the User is invited to consult their privacy policy.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website and, where technically and legally feasible, by sending a notification to Users through one of their contact details. Therefore, please consult this page frequently, referring to the date of last change indicated at the bottom.

If the changes affect processing operations whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Legal basis for processing your personal information

We only process your personal information if one of the legal bases for such processing is applied. The legal bases are as follows:

• your consent to the processing activities in question;
• the fulfilment of legal obligations that we are required to fulfil;
• the implementation of rules dictated by laws or regulations or contracts, agreements or other similar legal instruments;
• studies carried out by research organisations, preferably on anonymised personal information;
• the performance of a contract and its pre-contractual obligations, if you are a party to that contract;
• the exercise of our rights in court, in administrative procedures or in arbitrations;
• your or a third party’s defense or safety;
• health protection - in the context of procedures put in place by health sector entities or professionals;
• our legitimate interest, provided that your fundamental rights and freedoms do not override such interests; and
• credit protection.

To learn more about legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of personal information are processed, you can refer to the "Details on the processing of Personal Data" section in this document.

Why we process your personal information

To find out why we process your personal information, please refer to the sections "Details on the processing of Personal Data" and "Purposes of the Processing of Collected Data" in this document.

Your privacy rights in Brazil, how to submit a request and how it will be handled by us

Your Privacy Rights in Brazil

You have the right to:

• obtain confirmation of the existence of processing activities concerning your personal information;
  access your personal information;
• obtain rectification of your incomplete, inaccurate or outdated personal information;
• obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or information that is processed in breach of the provisions of the LGPD;
• obtain information about the possibility of giving or refusing your consent and its consequences;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your explicit request, the portability of your personal information (with the exception of anonymized information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions applies provided for in Article 16 LGPD;
• revoke your consent at any time;
• make a complaint about your personal information to the ANPD (National Data Protection Authority) or a consumer protection body;
• oppose processing activities in cases where such processing is not carried out in accordance with legal provisions;
• require clear and adequate information on the encryption and procedures used in automated decision-making processes; and
• request the review of decisions affecting your interests, carried out exclusively on the basis of automated decision-making processes of your personal information. These include decisions to outline your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you in any way be treated unfavourably, as a result of exercising your rights.

How to submit a request

You can make an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and how long we will handle your request

We will do our best to respond to your request as soon as possible.

In any case, if it is impossible for us to do so, we will ensure that we provide you with the factual or legal reasons that prevent us from fulfilling your request immediately or following up your request. If your personal information is not processed by us, if we are able to do so, we will inform you of the natural or legal person to whom your requests are addressed.

If you decide to submit a request for access or a request for confirmation of the existence of processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.

You’ll also need to let us know if you want an immediate response, in which case you’ll receive a simplified response, or if you need a full response.

In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, the confirmation or not of the existence of personal information about you, all the criteria used for the processing and the purposes of such processing, while safeguarding our business and industrial secrets.

If you decide to submit a request for rectification, cancellation, anonymization or blocking of personal information, we will make sure to inform immediately of your request the other parties with whom we have shared your personal information so that they can in turn fulfill your request - except where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside of Brazil in cases permitted by law

We may transfer your personal information outside of Brazil in the following cases:

where the transfer is necessary for international legal cooperation between intelligence, investigative and criminal procedure services, as provided for in
instruments made available under international law;

when the transfer is necessary to defend the life or physical safety of you or third parties;
where the transfer is authorised by the ANPD;

where the transfer is the result of an obligation under an international cooperation agreement;
where the transfer is necessary for the exercise of a public policy or for the performance of a public service;
when the transfer is necessary for the fulfilment of a legal obligation, the execution of a contract and the related pre-contractual fulfillments, or the normal exercise of rights in the leadership, administrative or arbitration.

Definitions and legal references

Personal Data (or Data)

Personal data are any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identifiable or identifiable.

Usage Data

This information is automatically collected through this Web Site (also by third party applications integrated into this Web Site), including: the IP addresses or domain names of computers used by the User connecting to this Web Site, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (good end, error, etc.) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time of stay on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters related to the operating system and the IT environment of the User.

User

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

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)

The natural or legal person, the public authority, the service or other body which, individually or together with others, determines the purposes and means of processing personal data and the instruments adopted, including safety measures relating to 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 hardware or software tool by which Personal Data of Users is collected and processed.

Service

The Service provided by this Website as defined in its terms (if any) on this website/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookie

Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology - e.g. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting - allowing you to track Users, for example by collecting or saving information on your device.

Legal references

This Privacy Policy is drafted on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies exclusively to this Website.

You can lodge a complaint with the Data Protection Authority. Last modified: 14 February 2023