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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



--------------------------------------------------------------------------------

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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.

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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.

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