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Submitted URL: https://davispmo.com/
Effective URL: https://altonwoodpartners.com/
Submission: On December 16 via api from US — Scanned from US
Effective URL: https://altonwoodpartners.com/
Submission: On December 16 via api from US — Scanned from US
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Text Content
Main Menu * EVENTS * ABOUT * ARTICLES * EVENTS * ABOUT * ARTICLES CONTACT US THE ANSWERS YOU NEED. THE BREAKTHROUGHS YOU WANT. TAKING YOUR BUSINESS FROM AVERAGE TO EXCEPTIONAL IS HARD WORK. IT TAKES DEDICATION, PASSION, AND THE RIGHT TEAM. THAT'S WHERE WE COME IN. CONTACT US MOVING FORWARD... MOVING TOGETHER JOIN US FOR ONE OF UPCOMING EVENTS LEARN MORE 02.28.2024 CHAT AI: THE WAVE YOU CAN'T AFFORD TO MISS 02.14.2024 THE FUTURE OF TALENT ACQUISITION -AI IS YOUR TICKET TO SUCCESS All Events Begin at 1:00pm (EST) SIGN UP Don't get left behind. Sign up for our exclusive webinar tailored for small businesses, and discover how Chat AI can help you grow your business and stay ahead of the competition. Space is limited - Sign up now. Don't miss this exclusive webinar designed for small businesses, where you'll discover easy to use AI techniques to streamline your recruiting process and hiring process and attract the best-fit candidates. Space is limited - Sign up now. STEVE DAVIS Author & Speaker Managing Partner WE START WITH YOU WE CENTER OUR COMPREHENSIVE APPROACH ON YOU AND YOUR YOUR NEEDS, TAKING THE TIME TO UNDERSTAND YOUR CHALLENGES, GOALS, AND VISION FOR THE FUTURE. THE ALTON WOOD ADVANTAGE OUR 4 STAGES DRIVE YOUR SUCCESS 1.ANALYZE FOR ACTION Starting with where you currently are, we thoroughly survey your current business environment. 2.BLUEPRINT & BUILD Next, we design a customized "ready to implement" blueprint... then we build it.. 3.POLISH & PERFECT Then, we focus on fine-tuning and optimizing performance 4.SUPPORT & SUSTAIN Finally, we’ll by there for you to ensure long term success 1. ANALYZE FOR ACTION WE START BY ANALYZING YOUR CURRENT BUSINESS, COMPETITORS, AND MARKET TRENDS. THIS DATA-DRIVEN ASSESSMENT WILL PROVIDE VALUABLE INSIGHTS INTO YOUR COMPANY'S STRENGTHS, WEAKNESSES, OPPORTUNITIES, AND POTENTIAL THREATS. BY INCLUDING THE COMPETITIVE LANDSCAPE AND INDUSTRY DYNAMICS, WE’LL DEVELOP TAILORED STRATEGIES AND SOLUTIONS THAT ALIGN WITH YOUR UNIQUE BUSINESS OBJECTIVES AND DRIVE SUCCESS. USING EVIDENCE, EXPERTISE, AND EXPERIENCE WE CREATE EXCELLENCE 2. BLUEPRINT & BUILD THE VALUE OF OUR BREAKTHROUGH PLANS IS IN THEIR PRACTICALITY, SCALABILITY, ADAPTABILITY, AND CUSTOMIZATION, ENSURING TOTAL ALIGNMENT WITH YOUR UNIQUE BUSINESS NEEDS. 01. ACTIONABLE We're not about vague theories and empty promises. Our Breakthrough Plans are all about action. We roll up our sleeves and work side by side with you to identify practical steps you can take right away. We break down big ideas into bite-sized tasks, providing you with a clear Blueprint to follow. Together, we'll bring those dreams to life and achieve real, tangible results. It's all about putting ideas into motion and making things happen. 02. SCALABLE Your business isn't static, and your plan shouldn’t be either Our Breakthrough Plans are built to grow with you. We create strategies that are flexible and adaptable, allowing you to scale up as your business expands. Whether you're looking to explore new horizons, expand your reach, or embrace fresh possibilities, we've got you covered. Our scalable approach ensures that your Breakthrough plan keeps pace with your ambitions, enabling you to seize new opportunities along the way. 03. CUSTOMIZED At Alton Wood Partners, we know that your business is one-of-a-kind. That's why our Breakthrough Plans are all about you. We dig deep into your business's DNA, understanding your unique challenges, goals, and dreams. By delving into your business intricacies, we craft a plan that perfectly fits your needs, unleashing your full potential. No cookie-cutter solutions here—just a tailor-made Blueprint designed to take your business to the next level. 04. ADAPTABLE In today's ever-changing business landscape, adaptability is key. Our Breakthrough Plans are designed to be flexible, helping you navigate through unexpected twists and turns. We understand that plans may need adjustments as you go, and that's why we're here for you every step of the way. We'll closely monitor your progress, fine-tuning the plan to align with shifting circumstances. With our adaptable approach, you'll stay ahead of the curve, embracing change and turning challenges into opportunities. 3. POLISH & PROTECT PRECISE REFINEMENT We roll up our sleeves and fine-tune all aspects of your processes to ensure they operate at their absolute best. DATA-DRIVEN We rely on the power of data to guide our refinements, making informed decisions that lead to enhanced efficiency and performance. CONTINUOUS FEEDBACK We establish a continuous feedback loop that keeps the team connected. This ongoing collaboration ensures that as your business evolves, so do your processes, keeping them running smoothly. BLUEPRINT. BREAKTHROUGH. BLISS. 4. SUPPORT & SUSTAIN WE RECOGNIZE THAT THE SHEER NUMBER OF TASKS IT TAKES TO MANAGE YOUR BUSINESS CAN BE OVERWHELMING. WE’RE HERE TO HELP. OUR OFFERINGS INCLUDE: Admin Duties Management Customer Relationship Management Technology Management Forcasting Development of new markets Marketing Management Training & Support Reporting Supportive Community OUR INSIGHTS . . . SHARED ARTICLE AI FOR SMALL BUSINESSES: HELP OR HYPE? READ MORE 11 JUL 2023 Wearsie Jackson Staff Writer ARTICLE DATA IS ALWAYS KING... UNTIL IT ISN'T. READ MORE 15 APR 2023 Dodo Brown Staff Writer ARTICLE ORGANIZED, FOR ORGANIZATION'S SAKE. READ MORE 06 MAY 2023 Relly Knodd Guest Writer LET'S TALK CONTACT. CONNECT. COLLAB. Name* Business Name* Email* Phone* Message (Optional) SUBMIT -------------------------------------------------------------------------------- Home Contact Terms & Conditions Privacy & Cookie Policy Affiliate Policy Photo Credits: hjD Studios, www.Freepik.com, Unsplash , Flicker 2024 Alton Wood Partners, LLC. All rights reserved. ALTON WOOD PARTNERS LLC · WILMINGTON, DELAWARE 19807 PRIVACY POLICY PRIVACY POLICY OF WWW.ALTONWOODPARTNERS.COM This Website collects some Personal Data from its Users. This document contains a section dedicated to Users in the United States and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser. POLICY SUMMARY PERSONAL DATA PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES: * * ANALYTICS * GOOGLE ANALYTICS (UNIVERSAL ANALYTICS), GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP AND ANALYTICS COLLECTED DIRECTLY Personal Data: Tracker; Usage Data * GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service * GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) * GOOGLE ANALYTICS FOR FIREBASE Personal Data: Usage Data * USER ID EXTENSION FOR GOOGLE ANALYTICS Personal Data: Tracker * GOOGLE ANALYTICS 4 Personal Data: browser information; city; device information; session statistics; Trackers; Usage Data * CONTACTING THE USER * CONTACT FORM Personal Data: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code * DISPLAYING CONTENT FROM EXTERNAL PLATFORMS * GOOGLE FONTS Personal Data: Tracker; Usage Data * REMARKETING AND BEHAVIORAL TARGETING * REMARKETING WITH GOOGLE ANALYTICS AND GOOGLE SIGNALS Personal Data: Tracker; Usage Data * TAG MANAGEMENT * GOOGLE TAG MANAGER AND ADOBE LAUNCH Personal Data: Usage Data * ADOBE DTM Personal Data: Trackers; Usage Data * SEGMENT Personal Data: Tracker; Usage Data * TRAFFIC OPTIMIZATION AND DISTRIBUTION * CLOUDFLARE Personal Data: Trackers 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. CONTACT INFORMATION * * OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com FULL POLICY OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com TYPES OF DATA COLLECTED Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; company name; physical address; state; email address; ZIP/Postal code; city; number of employees; device information; session statistics; browser information. 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. Users are responsible for any third-party Personal Data obtained, published or shared through this Website. 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. 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. RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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: Tag Management, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Contacting the User and Traffic optimization and distribution. 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 (UNIVERSAL ANALYTICS) (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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 order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in the United States GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES (GOOGLE LLC) Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS (GOOGLE LLC) Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS FOR FIREBASE (GOOGLE LLC) Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE LLC) Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well. Personal Data processed: Tracker. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ANALYTICS COLLECTED DIRECTLY (THIS WEBSITE) This Website uses an internal analytics system that does not involve third parties. Personal Data processed: Tracker; Usage Data. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: GOOGLE ANALYTICS 4 (GOOGLE LLC) Google Analytics 4 is a web analysis service provided by Google LLC (“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. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: browser information; city; device information; session statistics; Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California * CONTACTING THE USER CONTACT 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: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code. Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; inferences drawn from other personal information. This processing constitutes: * 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 FONTS (GOOGLE LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Trackers with the Google Ads advertising network and the Doubleclick Cookie. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California GOOGLE SIGNALS (GOOGLE LLC) This Website uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Website with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California * 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 LLC) Google Tag Manager is a tag management service provided by Google LLC. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE DTM (ADOBE SYSTEMS INCORPORATED) Adobe DTM is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE LAUNCH (ADOBE SYSTEMS INCORPORATED) Adobe Launch is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California SEGMENT (TWILIO, INC.) Segment is a tag management service provided by Twilio, Inc. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Cloudflare 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: Trackers. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California 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. COOKIE POLICY This Website uses Trackers. To learn more, Users may consult the Cookie Policy. FURTHER INFORMATION FOR USERS 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. * 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. FURTHER INFORMATION ABOUT RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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 fulfil 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 RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR) Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: * 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. * 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 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 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. * Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Users are also entitled to learn about the legal basis for Data transfers abroad including 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. 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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. FURTHER INFORMATION FOR USERS IN THE UNITED STATES 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information. NOTICE AT COLLECTION The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected. * INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION Personal Information collected or disclosed: Usage Data, Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Trackers, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, device information, session statistics, browser information Purposes: * Tag Management * Analytics * Remarketing and behavioral targeting * Displaying content from external platforms * Contacting the User * Traffic optimization and distribution Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC, Adobe Systems Incorporated, Twilio, Inc., Cloudflare Inc. Service providers or contractors: this Website * IDENTIFIERS Personal Information collected or disclosed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data, Trackers, device information, session statistics, browser information Purposes: * Analytics * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC Service providers or contractors: this Website * COMMERCIAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website * INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy. To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy. For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy. We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent. 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 Website and features thereof. YOUR PRIVACY RIGHTS UNDER US STATE LAWS You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have: * the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; * the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; * the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; * the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible; * the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights. * the right to non-discrimination. ADDITIONAL RIGHTS FOR USERS RESIDING IN CALIFORNIA In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have * The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; * The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service. ADDITIONAL RIGHTS FOR USERS RESIDING IN VIRGINIA, COLORADO, CONNECTICUT, TEXAS, OREGON, NEVADA, DELAWARE, IOWA, NEW HAMPSHIRE, NEW JERSEY, NEBRASKA AND MONTANA In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have * The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; * The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. ADDITIONAL RIGHTS FOR USERS RESIDING IN UTAH AND IOWA In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have * The right to opt out of the processing of your Personal Information for Targeted Advertising; * The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. HOW TO EXERCISE YOUR PRIVACY RIGHTS UNDER US STATE LAWS 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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority. HOW TO EXERCISE YOUR RIGHTS TO OPT OUT In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website. If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner. HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them. 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. 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. DEFINITIONS AND LEGAL REFERENCES PERSONAL DATA (OR DATA) / PERSONAL INFORMATION (OR INFORMATION) 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. SENSITIVE PERSONAL INFORMATION Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law. 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 PROCESSOR) 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. SALE Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information. SHARING 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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information. TARGETED ADVERTISING Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law. 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. This privacy policy relates solely to this Website, if not stated otherwise within this document. Latest update: September 10, 2023 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. PRIVACY POLICY OF WWW.ALTONWOODPARTNERS.COM This Website collects some Personal Data from its Users. This document contains a section dedicated to Users in the United States and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser. POLICY SUMMARY PERSONAL DATA PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES: * * ANALYTICS * GOOGLE ANALYTICS (UNIVERSAL ANALYTICS), GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP AND ANALYTICS COLLECTED DIRECTLY Personal Data: Tracker; Usage Data * GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service * GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) * GOOGLE ANALYTICS FOR FIREBASE Personal Data: Usage Data * USER ID EXTENSION FOR GOOGLE ANALYTICS Personal Data: Tracker * GOOGLE ANALYTICS 4 Personal Data: browser information; city; device information; session statistics; Trackers; Usage Data * CONTACTING THE USER * CONTACT FORM Personal Data: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code * DISPLAYING CONTENT FROM EXTERNAL PLATFORMS * GOOGLE FONTS Personal Data: Tracker; Usage Data * REMARKETING AND BEHAVIORAL TARGETING * REMARKETING WITH GOOGLE ANALYTICS AND GOOGLE SIGNALS Personal Data: Tracker; Usage Data * TAG MANAGEMENT * GOOGLE TAG MANAGER AND ADOBE LAUNCH Personal Data: Usage Data * ADOBE DTM Personal Data: Trackers; Usage Data * SEGMENT Personal Data: Tracker; Usage Data * TRAFFIC OPTIMIZATION AND DISTRIBUTION * CLOUDFLARE Personal Data: Trackers 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. CONTACT INFORMATION * * OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com FULL POLICY OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com TYPES OF DATA COLLECTED Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; company name; physical address; state; email address; ZIP/Postal code; city; number of employees; device information; session statistics; browser information. 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. Users are responsible for any third-party Personal Data obtained, published or shared through this Website. 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. 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. RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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: Tag Management, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Contacting the User and Traffic optimization and distribution. 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 (UNIVERSAL ANALYTICS) (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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 order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in the United States GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES (GOOGLE LLC) Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS (GOOGLE LLC) Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS FOR FIREBASE (GOOGLE LLC) Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE LLC) Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well. Personal Data processed: Tracker. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ANALYTICS COLLECTED DIRECTLY (THIS WEBSITE) This Website uses an internal analytics system that does not involve third parties. Personal Data processed: Tracker; Usage Data. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: GOOGLE ANALYTICS 4 (GOOGLE LLC) Google Analytics 4 is a web analysis service provided by Google LLC (“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. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: browser information; city; device information; session statistics; Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California * CONTACTING THE USER CONTACT 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: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code. Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; inferences drawn from other personal information. This processing constitutes: * 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 FONTS (GOOGLE LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Trackers with the Google Ads advertising network and the Doubleclick Cookie. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California GOOGLE SIGNALS (GOOGLE LLC) This Website uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Website with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California * 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 LLC) Google Tag Manager is a tag management service provided by Google LLC. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE DTM (ADOBE SYSTEMS INCORPORATED) Adobe DTM is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE LAUNCH (ADOBE SYSTEMS INCORPORATED) Adobe Launch is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California SEGMENT (TWILIO, INC.) Segment is a tag management service provided by Twilio, Inc. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Cloudflare 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: Trackers. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California 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. COOKIE POLICY This Website uses Trackers. To learn more, Users may consult the Cookie Policy. FURTHER INFORMATION FOR USERS 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. * 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. FURTHER INFORMATION ABOUT RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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 fulfil 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 RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR) Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: * 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. * 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 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 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. * Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Users are also entitled to learn about the legal basis for Data transfers abroad including 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. 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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. FURTHER INFORMATION FOR USERS IN THE UNITED STATES 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information. NOTICE AT COLLECTION The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected. * INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION Personal Information collected or disclosed: Usage Data, Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Trackers, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, device information, session statistics, browser information Purposes: * Tag Management * Analytics * Remarketing and behavioral targeting * Displaying content from external platforms * Contacting the User * Traffic optimization and distribution Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC, Adobe Systems Incorporated, Twilio, Inc., Cloudflare Inc. Service providers or contractors: this Website * IDENTIFIERS Personal Information collected or disclosed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data, Trackers, device information, session statistics, browser information Purposes: * Analytics * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC Service providers or contractors: this Website * COMMERCIAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website * INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy. To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy. For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy. We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent. 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 Website and features thereof. YOUR PRIVACY RIGHTS UNDER US STATE LAWS You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have: * the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; * the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; * the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; * the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible; * the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights. * the right to non-discrimination. ADDITIONAL RIGHTS FOR USERS RESIDING IN CALIFORNIA In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have * The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; * The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service. ADDITIONAL RIGHTS FOR USERS RESIDING IN VIRGINIA, COLORADO, CONNECTICUT, TEXAS, OREGON, NEVADA, DELAWARE, IOWA, NEW HAMPSHIRE, NEW JERSEY, NEBRASKA AND MONTANA In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have * The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; * The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. ADDITIONAL RIGHTS FOR USERS RESIDING IN UTAH AND IOWA In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have * The right to opt out of the processing of your Personal Information for Targeted Advertising; * The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. HOW TO EXERCISE YOUR PRIVACY RIGHTS UNDER US STATE LAWS 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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority. HOW TO EXERCISE YOUR RIGHTS TO OPT OUT In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website. If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner. HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them. 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. 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. DEFINITIONS AND LEGAL REFERENCES PERSONAL DATA (OR DATA) / PERSONAL INFORMATION (OR INFORMATION) 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. SENSITIVE PERSONAL INFORMATION Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law. 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 PROCESSOR) 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. SALE Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information. SHARING 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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information. TARGETED ADVERTISING Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law. 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. This privacy policy relates solely to this Website, if not stated otherwise within this document. Latest update: September 10, 2023 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. PRIVACY POLICY OF WWW.ALTONWOODPARTNERS.COM This Website collects some Personal Data from its Users. This document contains a section dedicated to Users in the United States and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser. POLICY SUMMARY PERSONAL DATA PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES: * * ANALYTICS * GOOGLE ANALYTICS (UNIVERSAL ANALYTICS), GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP AND ANALYTICS COLLECTED DIRECTLY Personal Data: Tracker; Usage Data * GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service * GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) * GOOGLE ANALYTICS FOR FIREBASE Personal Data: Usage Data * USER ID EXTENSION FOR GOOGLE ANALYTICS Personal Data: Tracker * GOOGLE ANALYTICS 4 Personal Data: browser information; city; device information; session statistics; Trackers; Usage Data * CONTACTING THE USER * CONTACT FORM Personal Data: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code * DISPLAYING CONTENT FROM EXTERNAL PLATFORMS * GOOGLE FONTS Personal Data: Tracker; Usage Data * REMARKETING AND BEHAVIORAL TARGETING * REMARKETING WITH GOOGLE ANALYTICS AND GOOGLE SIGNALS Personal Data: Tracker; Usage Data * TAG MANAGEMENT * GOOGLE TAG MANAGER AND ADOBE LAUNCH Personal Data: Usage Data * ADOBE DTM Personal Data: Trackers; Usage Data * SEGMENT Personal Data: Tracker; Usage Data * TRAFFIC OPTIMIZATION AND DISTRIBUTION * CLOUDFLARE Personal Data: Trackers 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. CONTACT INFORMATION * * OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com FULL POLICY OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com TYPES OF DATA COLLECTED Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; company name; physical address; state; email address; ZIP/Postal code; city; number of employees; device information; session statistics; browser information. 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. Users are responsible for any third-party Personal Data obtained, published or shared through this Website. 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. 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. RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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: Tag Management, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Contacting the User and Traffic optimization and distribution. 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 (UNIVERSAL ANALYTICS) (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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 order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in the United States GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES (GOOGLE LLC) Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS (GOOGLE LLC) Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS FOR FIREBASE (GOOGLE LLC) Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE LLC) Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well. Personal Data processed: Tracker. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ANALYTICS COLLECTED DIRECTLY (THIS WEBSITE) This Website uses an internal analytics system that does not involve third parties. Personal Data processed: Tracker; Usage Data. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: GOOGLE ANALYTICS 4 (GOOGLE LLC) Google Analytics 4 is a web analysis service provided by Google LLC (“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. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: browser information; city; device information; session statistics; Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California * CONTACTING THE USER CONTACT 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: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code. Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; inferences drawn from other personal information. This processing constitutes: * 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 FONTS (GOOGLE LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Trackers with the Google Ads advertising network and the Doubleclick Cookie. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California GOOGLE SIGNALS (GOOGLE LLC) This Website uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Website with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California * 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 LLC) Google Tag Manager is a tag management service provided by Google LLC. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE DTM (ADOBE SYSTEMS INCORPORATED) Adobe DTM is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE LAUNCH (ADOBE SYSTEMS INCORPORATED) Adobe Launch is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California SEGMENT (TWILIO, INC.) Segment is a tag management service provided by Twilio, Inc. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Cloudflare 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: Trackers. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California 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. COOKIE POLICY This Website uses Trackers. To learn more, Users may consult the Cookie Policy. FURTHER INFORMATION FOR USERS 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. * 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. FURTHER INFORMATION ABOUT RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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 fulfil 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 RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR) Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: * 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. * 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 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 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. * Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Users are also entitled to learn about the legal basis for Data transfers abroad including 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. 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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. FURTHER INFORMATION FOR USERS IN THE UNITED STATES 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information. NOTICE AT COLLECTION The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected. * INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION Personal Information collected or disclosed: Usage Data, Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Trackers, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, device information, session statistics, browser information Purposes: * Tag Management * Analytics * Remarketing and behavioral targeting * Displaying content from external platforms * Contacting the User * Traffic optimization and distribution Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC, Adobe Systems Incorporated, Twilio, Inc., Cloudflare Inc. Service providers or contractors: this Website * IDENTIFIERS Personal Information collected or disclosed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data, Trackers, device information, session statistics, browser information Purposes: * Analytics * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC Service providers or contractors: this Website * COMMERCIAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website * INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy. To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy. For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy. We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent. 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 Website and features thereof. YOUR PRIVACY RIGHTS UNDER US STATE LAWS You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have: * the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; * the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; * the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; * the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible; * the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights. * the right to non-discrimination. ADDITIONAL RIGHTS FOR USERS RESIDING IN CALIFORNIA In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have * The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; * The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service. ADDITIONAL RIGHTS FOR USERS RESIDING IN VIRGINIA, COLORADO, CONNECTICUT, TEXAS, OREGON, NEVADA, DELAWARE, IOWA, NEW HAMPSHIRE, NEW JERSEY, NEBRASKA AND MONTANA In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have * The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; * The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. ADDITIONAL RIGHTS FOR USERS RESIDING IN UTAH AND IOWA In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have * The right to opt out of the processing of your Personal Information for Targeted Advertising; * The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. HOW TO EXERCISE YOUR PRIVACY RIGHTS UNDER US STATE LAWS 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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority. HOW TO EXERCISE YOUR RIGHTS TO OPT OUT In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website. If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner. HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them. 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. 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. DEFINITIONS AND LEGAL REFERENCES PERSONAL DATA (OR DATA) / PERSONAL INFORMATION (OR INFORMATION) 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. SENSITIVE PERSONAL INFORMATION Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law. 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 PROCESSOR) 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. SALE Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information. SHARING 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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information. TARGETED ADVERTISING Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law. 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. This privacy policy relates solely to this Website, if not stated otherwise within this document. Latest update: September 10, 2023 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. PRIVACY POLICY PRIVACY POLICY OF WWW.ALTONWOODPARTNERS.COM This Website collects some Personal Data from its Users. This document contains a section dedicated to Users in the United States and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser. POLICY SUMMARY PERSONAL DATA PROCESSED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES: * * ANALYTICS * GOOGLE ANALYTICS (UNIVERSAL ANALYTICS), GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP AND ANALYTICS COLLECTED DIRECTLY Personal Data: Tracker; Usage Data * GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service * GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) * GOOGLE ANALYTICS FOR FIREBASE Personal Data: Usage Data * USER ID EXTENSION FOR GOOGLE ANALYTICS Personal Data: Tracker * GOOGLE ANALYTICS 4 Personal Data: browser information; city; device information; session statistics; Trackers; Usage Data * CONTACTING THE USER * CONTACT FORM Personal Data: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code * DISPLAYING CONTENT FROM EXTERNAL PLATFORMS * GOOGLE FONTS Personal Data: Tracker; Usage Data * REMARKETING AND BEHAVIORAL TARGETING * REMARKETING WITH GOOGLE ANALYTICS AND GOOGLE SIGNALS Personal Data: Tracker; Usage Data * TAG MANAGEMENT * GOOGLE TAG MANAGER AND ADOBE LAUNCH Personal Data: Usage Data * ADOBE DTM Personal Data: Trackers; Usage Data * SEGMENT Personal Data: Tracker; Usage Data * TRAFFIC OPTIMIZATION AND DISTRIBUTION * CLOUDFLARE Personal Data: Trackers 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. CONTACT INFORMATION * * OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com FULL POLICY OWNER AND DATA CONTROLLER Alton Wood Partners, LLC · 4023 Kennett Pike #431 · Wilmington, DE 19807 Owner contact email: policies34@altonwoodpartners.com TYPES OF DATA COLLECTED Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); first name; last name; phone number; company name; physical address; state; email address; ZIP/Postal code; city; number of employees; device information; session statistics; browser information. 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. Users are responsible for any third-party Personal Data obtained, published or shared through this Website. 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. 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. RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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: Tag Management, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Contacting the User and Traffic optimization and distribution. 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 (UNIVERSAL ANALYTICS) (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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 order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in the United States GOOGLE ANALYTICS ADVERTISING REPORTING FEATURES (GOOGLE LLC) Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS DEMOGRAPHICS AND INTERESTS REPORTS (GOOGLE LLC) Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google's use of cookies by visiting Google's Ads Settings. Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example). Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS FOR FIREBASE (GOOGLE LLC) Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California GOOGLE ANALYTICS (UNIVERSAL ANALYTICS) WITH ANONYMIZED IP (GOOGLE LLC) Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“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. This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California USER ID EXTENSION FOR GOOGLE ANALYTICS (GOOGLE LLC) Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device. The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website. The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well. Personal Data processed: Tracker. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ANALYTICS COLLECTED DIRECTLY (THIS WEBSITE) This Website uses an internal analytics system that does not involve third parties. Personal Data processed: Tracker; Usage Data. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: GOOGLE ANALYTICS 4 (GOOGLE LLC) Google Analytics 4 is a web analysis service provided by Google LLC (“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. In order to understand Google's use of Data, consult Google's partner policy. Personal Data processed: browser information; city; device information; session statistics; Trackers; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information. This processing constitutes: * a Sale in California * CONTACTING THE USER CONTACT 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: city; company name; email address; first name; last name; number of employees; phone number; physical address; state; Usage Data; ZIP/Postal code. Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; inferences drawn from other personal information. This processing constitutes: * 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 FONTS (GOOGLE LLC) Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Trackers with the Google Ads advertising network and the Doubleclick Cookie. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California GOOGLE SIGNALS (GOOGLE LLC) This Website uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Website with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * a Sharing in California * 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 LLC) Google Tag Manager is a tag management service provided by Google LLC. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE DTM (ADOBE SYSTEMS INCORPORATED) Adobe DTM is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Trackers; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California ADOBE LAUNCH (ADOBE SYSTEMS INCORPORATED) Adobe Launch is a tag management service provided by Adobe Systems Incorporated. Personal Data processed: Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California SEGMENT (TWILIO, INC.) Segment is a tag management service provided by Twilio, Inc. Personal Data processed: Tracker; Usage Data. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California * 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 Cloudflare 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: Trackers. Place of processing: United States – Privacy Policy. Category of Personal Information collected according to the CCPA: internet or other electronic network activity information. This processing constitutes: * a Sale in California 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. COOKIE POLICY This Website uses Trackers. To learn more, Users may consult the Cookie Policy. FURTHER INFORMATION FOR USERS 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. * 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. FURTHER INFORMATION ABOUT RETENTION TIME Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. 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 fulfil 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 RIGHTS OF USERS BASED ON THE GENERAL DATA PROTECTION REGULATION (GDPR) Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: * 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. * 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 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 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. * Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. Users are also entitled to learn about the legal basis for Data transfers abroad including 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. 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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients. FURTHER INFORMATION FOR USERS IN THE UNITED STATES 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information. NOTICE AT COLLECTION The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected. * INTERNET OR OTHER ELECTRONIC NETWORK ACTIVITY INFORMATION Personal Information collected or disclosed: Usage Data, Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Trackers, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, device information, session statistics, browser information Purposes: * Tag Management * Analytics * Remarketing and behavioral targeting * Displaying content from external platforms * Contacting the User * Traffic optimization and distribution Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC, Adobe Systems Incorporated, Twilio, Inc., Cloudflare Inc. Service providers or contractors: this Website * IDENTIFIERS Personal Information collected or disclosed: Tracker, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data, Trackers, device information, session statistics, browser information Purposes: * Analytics * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Third-parties: Google LLC Service providers or contractors: this Website * COMMERCIAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website * INFERENCES DRAWN FROM OTHER PERSONAL INFORMATION Personal Information collected or disclosed: first name, last name, phone number, company name, physical address, state, email address, ZIP/Postal code, city, number of employees, Usage Data Purposes: * Contacting the User Retention period: for the time necessary to fulfill the purpose Sold or Shared ℹ️: Yes Targeted Advertising: ℹ️: Yes Service providers or contractors: this Website ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy. To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy. For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy. We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent. 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 Website and features thereof. YOUR PRIVACY RIGHTS UNDER US STATE LAWS You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have: * the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information; * the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you; * the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information; * the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible; * the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights. * the right to non-discrimination. ADDITIONAL RIGHTS FOR USERS RESIDING IN CALIFORNIA In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have * The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising; * The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service. ADDITIONAL RIGHTS FOR USERS RESIDING IN VIRGINIA, COLORADO, CONNECTICUT, TEXAS, OREGON, NEVADA, DELAWARE, IOWA, NEW HAMPSHIRE, NEW JERSEY, NEBRASKA AND MONTANA In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have * The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; * The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. ADDITIONAL RIGHTS FOR USERS RESIDING IN UTAH AND IOWA In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have * The right to opt out of the processing of your Personal Information for Targeted Advertising; * The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. HOW TO EXERCISE YOUR PRIVACY RIGHTS UNDER US STATE LAWS 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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority. HOW TO EXERCISE YOUR RIGHTS TO OPT OUT In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website. If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner. HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need. Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint). We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them. 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. 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. DEFINITIONS AND LEGAL REFERENCES PERSONAL DATA (OR DATA) / PERSONAL INFORMATION (OR INFORMATION) 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. SENSITIVE PERSONAL INFORMATION Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law. 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 PROCESSOR) 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. SALE Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information. SHARING 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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information. TARGETED ADVERTISING Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law. 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. This privacy policy relates solely to this Website, if not stated otherwise within this document. Latest update: September 10, 2023 iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided. Close menu