Privacy Policy

Owner and Data Controller

Innovation Online Ltd
Tallis House, 2 Tallis Street, EC4Y 0AB London (UK)

Owner contact email: servizioclienti@letterasenzabusta.com

Types of Data collected

Among the types of Personal Data that LetteraSenzaBusta.com collects, by itself or through third parties, there are: first name, last name, gender, date of birth, phone number, address, email address, Social Security number (SSN), company name, VAT Number, Cookies, Usage Data, Various types of Data, Contacts permission and Camera permission.

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 LetteraSenzaBusta.com.
Unless specified otherwise, all Data requested by LetteraSenzaBusta.com is mandatory and failure to provide this Data may make it impossible for LetteraSenzaBusta.com to provide its services. In cases where LetteraSenzaBusta.com 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 LetteraSenzaBusta.com or by the owners of third-party services used by LetteraSenzaBusta.com 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 LetteraSenzaBusta.com 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 LetteraSenzaBusta.com (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 to 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 Services, as well as for the following purposes: Registration and authentication, Handling payments, Analytics, Advertising, Contacting the User, Social features, Interaction with live chat platforms, Device permissions for Personal Data access and Managing contacts and sending messages.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Device permissions for Personal Data access

Depending on the User's specific device, LetteraSenzaBusta.com may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of LetteraSenzaBusta.com.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by LetteraSenzaBusta.com.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Detailed information on the processing of Personal Data

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

• Advertising

  This type of services allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on LetteraSenzaBusta.com, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside LetteraSenzaBusta.com. For more information, please check the privacy policies of the relevant services.

  Direct Email Marketing (DEM) (LetteraSenzaBusta.com)

  LetteraSenzaBusta.com uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by LetteraSenzaBusta.com.

  Personal Data collected: email address.

• 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 LetteraSenzaBusta.com, 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 collected: Cookies and Usage Data.

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

  Google AdWords conversion tracking (Google Inc.)

  Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on LetteraSenzaBusta.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Facebook Ads conversion tracking (Facebook, Inc.)

  Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on LetteraSenzaBusta.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Twitter Ads conversion tracking (Twitter, Inc.)

  Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on LetteraSenzaBusta.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Contacting the User

  Mailing List or Newsletter (LetteraSenzaBusta.com)

  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 LetteraSenzaBusta.com. Your email address might also be added to this list as a result of signing up to LetteraSenzaBusta.com or after making a purchase.

  Personal Data collected: email address.

• Device permissions for Personal Data access

  LetteraSenzaBusta.com requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (LetteraSenzaBusta.com)

  LetteraSenzaBusta.com requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data collected: Camera permission and Contacts permission.

• Handling payments

  Payment processing services enable LetteraSenzaBusta.com to process payments by credit card, bank transfer or other means. To ensure greater security, LetteraSenzaBusta.com shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials.

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

  SOFORT (SOFORT GmbH)

  SOFORT is a payment service provided by SOFORT GmbH.

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

  Place of processing: Germany – Privacy Policy.

  Stripe (Stripe Inc)

  Stripe is a payment service provided by Stripe Inc.

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

  Place of processing: US – Privacy Policy.

  Bitpay (BitPay, Inc.)

  Bitpay is a payment service provided by BitPay, Inc.

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

  Place of processing: US – Privacy Policy.

• Interaction with live chat platforms

  This type of services allows Users to interact with third party live chat platforms directly from the pages of LetteraSenzaBusta.com, for contacting and being contacted by LetteraSenzaBusta.com 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.

  Pure Chat Widget (Pure Chat, Inc.)

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

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  AWeber (AWeber)

  AWeber is an email address management and message sending service provided by AWeber Systems Inc.

  Personal Data collected: email address.

  Place of processing: US – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow LetteraSenzaBusta.com to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, LetteraSenzaBusta.com will be able to access some Data, stored by these third party services, for registration or identification purposes.

  Direct registration (LetteraSenzaBusta.com)

  The User registers by filling out the registration form and providing the Personal Data directly to LetteraSenzaBusta.com.

  Personal Data collected: address, company name, date of birth, email address, first name, gender, last name, phone number, Social Security number (SSN) and VAT Number.

  Mobysign (ITside S.r.l)

  Mobysign is an authentication service provided by ITside S.r.l.
  In addition to its authentication capabilities, Mobysign may handle the User's Data regarding payments made on LetteraSenzaBusta.com in order to allow the Owner to process payment transactions by credit card, bank transfer or other means.

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

  Place of processing: Italy – Privacy Policy.

• Social features

  Inviting and suggesting friends (LetteraSenzaBusta.com)

  LetteraSenzaBusta.com may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

  Personal Data collected: Various types of Data.

Further information about Personal Data

• Data handling by commercial partners

  The Owner may share Data with commercial partners for the uses set out in this document or for commercial purposes. Further processing of Data, and the use thereof, shall be regulated by the partners' policies, which are not within the control of the Owner.

• Contact via phone

  Users who have provided their phone number may be contacted for purposes related to this website, as well as in response to requests for customer support. Users may not provide phone numbers of third parties, even if such parties consent. Any telephone numbers that are supplied must be the User’s exclusive property.
  
  Personal Data collected: Telephone Number.

• Direct signature

  The mobile application LetteraSenzaBusta.com has a feature that allows the User to sign their communications by simply tracing their signature with the finger on the smartphone screen. This Personal Datum is collected exclusively for the purpose of signing the documents and is never shared with third parties. The User who does not wish to use this service, can always use Mobysign or any other subscription options available on LetteraSenzaBusta.com.

• Honos (Land S.r.l.)

  Honos is a mobile application by Land S.r.l. which provides a reading technology of the QR code available in the “Certificato di Data Certa”.
  
  Place of Processing: Italy - Privacy Policy

• Linkedin Ads conversion tracking

  Linkedin Ads conversion tracking is an analytics service provided by Linkedin Corporation that connects data from the Linkedin advertising network with actions performed on LetteraSenzaBusta.com.
  
  Place of processing: USA - Privacy Policy

• Data processing by third-parties

  The Owner may use third-party services (*i.e.* Mobysign, Honos, Paypal *etc*.) for the provision of certain features available on LetteraSenzaBusta.com. In order to use such services, Users must register with the third-party and accept their privacy policy and terms of service.
  
  The User acknowledges and agrees that, processing of Data by such third-parties, and the use thereof, outside of the scope of the provision of the services offered by LetteraSenzaBusta.com, shall be regulated by the partners' policies, which are not within the control of the Owner.

• Provely (Digital Kickstart, LLC)

  Provely is a notification service provided by Digital Kickstart, LLC.
  Personal Data collected: Cookies and other Data according to what is stated in the privacy policy of the provider.
  Place of processing: US – Privacy Policy.

• PostmarK (Wildbit, LLC)

  Postmarkis an email address management and message sending service provided by Wildbit, LLC.
  Personal Data collected: email address.
  Place of processing: US – Privacy Policy.

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

LetteraSenzaBusta.com uses Cookies. To learn more and for a detailed cookie notice, 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 LetteraSenzaBusta.com 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, LetteraSenzaBusta.com 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, LetteraSenzaBusta.com and any third-party services may collect files that record interaction with LetteraSenzaBusta.com (System logs) 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

LetteraSenzaBusta.com 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 giving notice to its Users on this page and possibly within LetteraSenzaBusta.com 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.