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PRIVACY POLICY


INFORMATION ON THE PROCESSING OF PERSONAL DATA

Last updated: 12 March 2020

Who is the data controller

Your data are processed, as Data Controller, by Advice Global ltd, with
registered office at CMS House, Third Floor, St. Peter’s Street, San Gwann, SGN,
2310 MALTA , Tax Code and VAT no. 23269314 (hereinafter, “ADviceGlobal“). If you
wish to contact ADviceGlobal, please refer to the contact details at the bottom
of this page.

Where we collect your personal data

We process the following data:

 * * data that you have provided us through one of our sites that refer to this
     Privacy Policy (“Sites“);
   * data that have been provided to us by a third party (autonomous data
     controller) to whom you had previously provided, respectively, a specific
     consent for the communication of your data to third parties as well as for
     the processing of such data for the own promotional and marketing purposes
     of those third parties;
   * browsing data that we collect through our Sites (see section “Cookies”
     below).

What personal data we process

The personal data we process are:

 * * name and surname;
   * date of birth;
   * sex;
   * telephone number;
   * address and zip code;
   * email address;
   * IP address and other data useful to circumscribe the consent given;
   * browsing data (see section “Cookies” below).

Why and for what purposes we process your personal data

Depending on the case, ADviceGlobal recurs to a different legal ground for the
processing of your personal data. In particular, we may process your personal
data:

 * * on the basis of your specificconsent:
     * to send you marketing and promotional communications (via e-mail, fax,
       telephone, sms, WhatsApp and any other remote communication technology);
     * to communicate your personal data to third parties;
     * to transfer your personal data outside the European Union in cases where
       it is not possible to do it on the basis of another legal instruments to
       do so.
   * On the basis of our contractual or pre-contractual relationship, to fulfil
     our obligations and provide you with the services that you have subscribed
     to or provide a feedback to your requests.
   * On the basis of a legal obligation, to act in accordance with the law and
     ensure that everything is in order (e.g., if it is expressly requested by
     an authority to do so or if we need to carry out any processing for
     complying with the law, such as the case of any check that is needed
     vis-a-vis the opt-out register, if applicable) or to defend our right
     (e.g., to defend ourselves in the context of a judicial proceeding).
   * On the basis of our legitimate interest or the legitimate interest of a
     third party, provided that your fundamental interests, rights and freedoms
     do not prevail (e.g. to carry out the necessary processing for our research
     and development purposes; to send you communications concerning our
     activities; to send you other communications that do not require consent).

At any time you have the right to withdraw your consent, without affecting the
lawfulness of the processing that we have carried out before the withdrawal. You
can withdraw your consent for each of the purposes that underlying a processing
that is based on the consent (e.g., you can withdraw your consent to no longer
receive marketing communications and / or to prevent us from communicating your
data to third parties).

Who processes your personal data?

ADviceGlobal allows its workers, who are strictly linked to confidentiality
obligations, to become aware of your personal data and to process them in
accordance with the permitted purposes.

Furthermore, in compliance with existing legal obligations, ADviceGlobal uses
the services of third party suppliers, duly appointed as data processors. These
include, for example, email delivery service providers and data storage service
providers. In particular, ADviceGlobal has appointed the following suppliers as
data processors:

 * * Mapp Digital Italy Srl, with registered office in via Orseolo Pietro 12,
     Milan (MI), Italy.
   * FreeMedia Internet SL with headquarters in C / Filà Cordòn, 36. Pol. Ind.
     Cotes Altes Acoy (03804), Alicante, Spain.
   * Gidinet with headquarters in Via Medeghino, 15 – 20141 Milan (MI).
   * OVH SAS au capital de 10 174 560 € – RCS Lille Métropole 424 761 419 – Code
     APE 2620Z N° TVA: FR 22 424 761 – Siège social: 2 Rue Kellermann – 59100
     Roubaix – France
   * AdviceMe SRL with registered office in Circonvallazione Clodia 163/171,
     00195, Roma
   * Audience SERV GMBH with registered office in kemperplatz 1, 10785 Berlin,
     Germany.
   * We Love Data sp. Z o. o. with registered office in Krakow, ul. Okaszowska
     15/4, 31-713 Krakow
   * TheValueFactory SL with registered office in Avinguda Francese Cambo 21, 5,
     09003 Barcelona.

With regard to the suppliers that are established outside the territory of the
European Union, please read the section “Transfer of data outside the European
Union“.

To whom we communicate your personal data

Based on your consent to communicate your personal data to third parties, we may
communicate your data to third parties who fall into the following product
categories:

 * * services and products relating to the communications and technology sector
     and similar.
   * Finance and banking sector: financial entities, insurance, investment,
     social security and similar (for example you will receive promotions owned
     by T Dot UK)
   * Free Time: pay TV, editorial, sports, collecting, photography, gaming,
     transportation, navigation, tourism (hotels, tour operators, travel
     agencies, airlines, etc.), aerospace, gardening and other hobbies, lottery,
     competitions, communication and entertainment, art, music and similars.
   * Distribution and commerce: electronics, IT, image and sound, fashion,
     accessories, clothing, textiles, bazaars, cosmetics and sanitation,
     chemistry, pharmaceuticals and biotechnology, agro-food, supermarkets,
     drinks, office supplies, furnishings, and similars.
   * Automotive: products and services related to cars, industrial vehicles,
     scooters, cycles and motorcycles, trucks, mechanics and metallurgy, and
     similars.
   * Energy and water: products related to electricity, hydrocarbons, gas, water
     and utilities, and similars.
   * Education, training, education, universities, and similars.
   * Communication and services: advertising, marketing, event, consulting,
     advertising, PR agencies, advertising agencies, media centers,
     telecommunications, market research, mobile marketing agencies, and
     similars.
   * Ecology and environment.
   * Construction, civil engineering and real estate products / services:
     construction, decorations, home, design, real estate agencies, and
     similars.
   * Fairs and events, and similars.
   * IT, internet, e-commerce sites, and similars.

If you gave your consent to communicate your data to third parties and we
communicate it to them, note that from the moment they receive your data they
will begin to process your data as autonomous data controllers. This means that,
in addition to the rights that you can always exercise vis-a-vis ADviceGlobal,
you can also exercise your rights directly vis-a-vis them. For more information,
please refer to the privacy policy that will be provided to you by them.

How long do we keep your personal data?

ADviceGlobal put a big effort in ensuring that the personal data is processed in
compliance with the principles of proportionality and minimization. Therefore,
ADviceGlobal will not store your data beyond the time that is necessary in
relation to the purposes that are pursued. For example:

 * * if we realize that your e-mail address has been deactivated, we usually
     delete it in a short time, as well as any other data associated with it
     that we could not use for the purposes for which it was collected.
   * If the processing of your data is based on a contractual relationship with
     ADviceGlobal, we will delete your data after a certain period of time from
     the termination of the contractual relationship (depending on the specific
     case and the applicable limitation periods).
   * If we process your data on the basis of consent and you withdraw your
     consent, we will delete all your data, even if we may continue to keep some
     information for a certain period of time on the basis of legitimate
     interest and in order to be able to prove that we had obtained a valid
     consent to carry out all the treatments carried out until your withdrawal.

Transfers of personal data outside the European Union

In some limited cases, some processing of personal data may take place outside
the territory of the European Union, for example in the USA. In these cases, the
company recurs to all the legal instruments necessary to ensure adequate
protection for your personal data (e.g. by asking suppliers who have an extra-EU
establishment to sign the so-called Standard Contractual Clauses (which is a
contract that requires them to respect the same standard of protection for
personal data as in the European Union) or, if they are established in the USA,
to subscribe to the so-called Privacy Shield.

Cookies

Cookies are small text files stored locally in the temporary memory of your
browser, and then on your computer, for variable periods of time. Through
cookies you can record semi-permanent information about your preferences and
other technical data that allow easier navigation and greater ease of use and
effectiveness of the site. For example, cookies can be used to determine if a
connection has already been made between your computer and our sites. To your
guarantee, only the cookie stored on your computer is identified. In this case
it is a cd. technical or session cookies. In addition, we use third-party
profiling cookies to enable us to reach you with personalized advertising
messages. You can manage your cookie preferences directly within your browser,
including the ability to delete cookies installed in the past, even from this
site. To proceed in this way, you can find information on how to manage (and
delete) cookies with some of the most popular browsers for example at the
following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft
Internet Explorer. With reference to third-party profiling cookies, we use the
tools provided by Facebook, Outbrain, Taboola, Revcontent and Tune. Facebook
allows you, via the settings available on this page, to disable the features
that make it easier to place ADviceGlobal listings shown on Facebook. Outbrain
allows you, through the settings available on this page, to disable the
functions that facilitate the positioning of ADviceGlobal listings during your
web browsing. Taboola allows you, through the settings available on this page,
to disable the functions that facilitate the positioning of ADviceGlobal ads
during your web browsing. Revcontent allows you, through the settings available
on this page, to disable the functions that facilitate the positioning of
ADviceGlobal listings during your web browsing. Tune allows you, through the
settings available on this page, to disable the functions that facilitate the
positioning of ADviceGlobal listings during your web browsing. For more
information on cookies, including how to view those that have been set on the
device, how to manage and delete them, visit www.allaboutcookies.org.

Your rights

In your quality of data subject, you are granted with the right of access,
rectification, cancellation as well as the right to data portability, the right
to limit the processing and the right to object to the processing, where the
conditions for their applicability exist. In any case, if the processing is
carried out for marketing purposes, or is based on our legitimate interest, you
are allowed to object to the processing at any time. To help you know your
rights, below we provide a brief illustration of the rights that are granted to
you by the law:

 * * the right of access allows you to obtain confirmation that a processing of
     your personal data is in place and, if necessary, to access such data and
     all related information.
   * The right of rectification allows you to obtain the modification of
     inaccurate personal data concerning you without undue delay and, taking
     into account the purposes of the processing, to obtain the integration of
     incomplete personal data.
   * The right to erasure allows you to obtain the erasure of your data without
     undue delay (e.g. when your personal data are no longer necessary in
     relation to the purposes for which they were collected), subject to the
     exceptions provided for by the legislation applicable (e.g. when the
     retention of your data is necessary for compliance with legal obligations
     applicable to the data controller).
   * The right to data portability allows you, under certain circumstances
     provided for by the applicable legislation, to receive the personal data
     concerning you that you have provided to the data controller in a
     structured, commonly used and machine-readable format. You will be able to
     transmit this data to another data controller, provided that this right can
     be recognized in the light of the applicable legislation, and without
     prejudice to the case in which an injury to the rights and freedoms of
     others may result.
   * The right to limitation of processing allows you, under certain
     circumstances provided for by the applicable legislation, to obtain the
     limitation of the processing of your personal data. In such cases, the data
     controller may continue to process your data only in some cases, for
     example for the exercise of the right of defence or to protect the rights
     of another natural or legal person.
   * The right to object to the processing allows you, under certain
     circumstances provided for by the applicable legislation, to object to the
     processing of your personal data unless there are prevailing legitimate
     reasons, rights or freedoms that allow the data controller to continue the
     processing of your data. In any case, if there are reasons related to your
     particular situation, you are granted with the right to object to the
     processing of your personal data which is based on a legitimate interest of
     ADviceGlobal or of a third party. In such cases ADviceGlobal will cease the
     processing, unless there is a compelling legitimate reason to proceed with
     the processing.

At any time you have the right to contact the Data Protection Authority if you
believe you have not satisfactorily obtained a response from ADviceGlobal
regarding your rights or if you believe there is a violation of your rights.

How to contact us to exercise your rights

You can contact ADviceGlobal to exercise your rights at any time by submitting a
request by e-mail to customercare@adviceglobal.com.mt



Data Protection Officer (DPO)

To ensure the maximum protection of data subjects’ rights, and in accordance
with EU Regulation 679/2016 (“GDPR“), ADviceGlobal has appointed a Data
Protection Officer who can be contacted at the e-mail address
dpo@adviceglobal.com.mt



Copyright © 2024 Advice Global LTD CMS House, Third Floor, St. Peter’s Street,
San Gwann, SGN, 2310 MALTA. VAT MT23269314
 * Privacy Policy