We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
By "Personal data" we mean information about any individual or from which any individual is directly or indirectly identifiable. This inlcudes your personal details (e.g., name); demographic data (e.g., age); contact details (e.g., address); records of your consents; purchase details; information about your interactions with our content or advertising; and any views or opinions you provide to us. We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
By “Process”, “Processing” or “Processed” in the context of your personal data we mean anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
There are three types of personal data we or our partners may collect from you:
3. Online Behavioral Advertising (“OBA”) data collected by us or third parties we work with.
We may use analytics software (e.g. Google Analytics) to collect data and to better understand your behaviour on our site and your commercial preferences. This software may record information such as how often you use our website, the events that occur within the website, which product pages you visit or which products you buy, aggregated usage, performance data, and where you reached our site from.
Certain third parties (Google AdSense or Facebook) may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.
The specific providers we use for OBA are subject to constant change. Below you can find a list of some of the providers we use most often:
There are various reasons for which we collect your personal information.
When an account is created for you on your website, your purchases are more secure as they are password protected and have extra security measures added that will prevent malicious users to access your orders. We will also use this information to better administrate your account, improve your experience on the website by adding new features and services, to send you statements and invoices and/or verify that you satisfy the age restricition for certain products.
We may Process your User Information to contact you via email or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. We may also send you third party promotional content from one or more of our business partners.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.
We may disclose your User Information to other entities for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where IndieGala advises users of the possibility of such disclosure at the time they take the survey, IndieGala reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
Also, in order to store your personal data securely, we user third party software and databases that helps us to operate our store. This means that your data is safely stored (therefore also shared with) on third parties databases. The following list shows the current providers we use for this purpose but this list is subject to change at any time.
Due to the international nature of our business, we may need to transfer your User Information to third party providers as noted in the above sections, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
In compliance with applicable regulations, a system of anti-spam verification on the communication between users is active. The data entered may be verified for the sole purpose of identifying illegal activities or contents that do not comply with the IndieGala Terms of Service, but will not be processed or communicated for commercial or promotional purposes.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
Newsletter subscriptions are kept as long as you continue to consent to receive our newsletter.
Finally, we remind you that the data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which has been implemented through the EU Directive 2017/541 on anti-terrorism regulations.
If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some parts of the Service, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off by adjusting the permissions in your browser or mobile device. Please note that your opt out is limited to the browser and device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing or IndieGala’s ongoing business relations.
EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us via email at email@example.com. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
The data controller is IndieGala S.R.L. in person of its legal representative pro-tempore, with registered office located in Rome (IT), Via Bolzano, 15, VAT ID: IT 11660511004.
The data controller uses a Data Protection Officer (DPO) to monitor the protection of your personal data.
For any request related to your personal data, please see the DPO contact details below.
The person in charge of data protection (Data Protection Officer) pursuant to art. 37 of the GDPR is IndieGala's Legal Manager - Pasquale Basso.
We remind you that you can contact the DPO at any time and send any question or request regarding your personal data and respect your privacy by writing to firstname.lastname@example.org