PRIVACY POLICY

Complete Privacy Policy

Personal Data Controller
Sondelli Guitars
Vat ID 85-2588057
12400 Ventura Blvd 91604 Studio City (EE) United States
Principal’s email address: info@sondelliguitars.com

Method and place of processing of collected data

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
Unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or IT tools, with organisational methods and with logic strictly related to the purposes indicated.
In addition to the Principal, in some cases other subjects may have access to the Data involved in the organisation of this Web Site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Controller.
The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the data processing

The Data Controller processes Personal Data relating to the User in the event one of the following conditions is met:

  • The User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorised to process Personal Data without the User’s consent or any of the other legal bases specified below, until such time as the User’s consent is obtained or until the User objects (“opts out”) of such processing. This does not though apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
  • the processing is necessary for the performance of a legal obligation to which the Controller is subject to;
  • The processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on a legitimate interest, and in particular to specify whether the processing is based on the law, required by a contract or necessary to conclude a contract.

Place

The Data is processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located.
For additional information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain information on the location of the processing, the User may refer to the section on details on the processing of Personal Data.

You have the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation under public international law or formed by two or more countries, such as the
the UN, as well as on the security measures adopted by the Controller to protect the Data.

In the event that one of the transfers just described takes place, the User may refer to the respective sections of this respective sections of this document or request information from the Data Controller by contacting it at the contact details given above.

Data storage period

The Data is processed and stored for the time required by the purposes for which they were collected.
Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of such contract is completed;
  • I Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information on the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this period the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.

Purposes of Data Collection

The User’s Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Statistics, Contacting the User, Managing Users’ databases, Re-marketing and behavioural targeting and Displaying content from external platforms.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Details on the processing of Personal Data

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

Contacting the User

Contact form (this Application)
The User, by filling in the contact form with his or her Data, consents to the use of such Data to respond to requests for information, quotes, or of any other nature indicated in the header of the form.
Personal Data collected: postcode, city, surname, email, address, name, province, state and telephone number.

Mailing list or newsletter (this Application)
By registering to the mailing list or newsletter, the User’s e-mail address is automatically included in a list of contacts to whom e-mail messages containing information, including commercial and promotional information, relating to this Application may be sent. The User’s email address may also be added to this list as a result of registering with this Application or after making a purchase.
Personal data collected: email and name.

Interaction with social networks and external platforms

This type of services allows interactions with social networks, or other external platforms, directly from the pages of this Application.
Interactions and information acquired by this Application are in any case subject to the User’s privacy settings for each social network.
If a service for interacting with social networks is installed, it is possible that, even if Users do not use the service, it will collect traffic data on the pages where it is installed.

Like button and Facebook social widgets (Facebook, Inc.)
The “Like” button and Facebook social widgets are services for interaction with the social network Facebook, provided by Facebook, Inc
Personal data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Privacy Shield member.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services for interaction with the social network Twitter, provided by Twitter, Inc.
Personal Data Collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.  Privacy Shield member.

Linkedin Social Button and Widgets (LinkedIn Corporation)
The LinkedIn social button and widgets are services for interaction with the LinkedIn social network, provided by LinkedIn Corporation.
Personal Data Collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Policy. Privacy Shield member.

Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User’s behaviour.

Google Analytics (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracing and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualise and personalise the advertisements of its advertising network.

Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy Opt Out. Privacy Shield adherent

Conversion tracking by Facebook Ads (Facebook, Inc.)
Facebook Ads conversion tracking is a statistics service provided by Facebook, Inc. which links data from the Facebook Ads network with actions performed within this Application.
Personal data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Party to the Privacy Shield.

Displaying content from external platforms
This type of service makes it possible to display content hosted on external platforms directly from the pages of this Application and to interact with them.
If a service of this type is installed, it is possible that, even if Users do not use the service, it will collect traffic data relating to the pages where it is installed.

Widget Google Maps (Google Ireland Limited)
Google Maps is a map display service operated by Google Ireland Limited that allows this application to integrate such content into its pages.
Personal data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Party to the Privacy Shield.

Widget Video YouTube (Google Ireland Limited)
YouTube is a video content display service operated by Google Ireland Limited that allows this Application to integrate such content into its pages.
Personal data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Party to the Privacy Shield.

Further information on Personal Data

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, the User has the right to:

  • revoke consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed.
  • oppose to the processing of their Data. The User may object to the processing of his or her Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
  • access to your Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • erify and request rectification. The User may verify the accuracy of its Data and request that it be updated or corrected.
  • obtain the limitation of the processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than to preserve them.
  • obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of its Data by the Data Controller.
  • receive their Data or have them transferred to another owner. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another owner. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures related thereto.
  • Lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.
Users are reminded that if their Data is processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise the User’s rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.
Cookie Policy

This Website makes use of cookies. To find out more and to view the detailed information, the User can consult the Cookie Policy.

Further information on processing

Legal defence
Your Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of such proceedings in order to defend against misuse of this Website or its related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information
At the User’s request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance
For operational and maintenance purposes, this Website and any third party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Responses to “Do Not Track” requests
This Website does not support “Do Not Track” requests.
To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal data (or Data)
Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
This is the information collected automatically through this Web Site (including by third party applications integrated into this Web Site), including: IP addresses or domain names of computers used by the User who connects with this Web Site, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the name of the person making the request, the date and time of the request, the date and time of the reply. ), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User
The individual who uses this Web Site which, unless otherwise specified, coincides with the Interested Party.

Interested Party
The natural person to whom the Personal Data refer.

Data Processor
The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Principal)
The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to 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 hardware or software tool through which Users’ Personal Data are collected and processed.

Service
The Service provided by this Website as defined in the relevant terms (if any) on this website/application.

European Union (or EU)
Unless otherwise specified, any reference in this document to the European Union shall be deemed to include all current member states of the European Union and the European Economic Area.

Cookie
A small piece of data stored on the User’s device.

Legal references
This privacy policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy relates exclusively to this Website.

Information on the processing of Personal Data submitted through Google Forms

Pursuant to articles 13-14 of the GDPR 2016/679

This information constitutes an integral part of our general Privacy Policy.

We inform you that the data you provide when completing the “Google Forms” questionnaire will be processed in accordance with the provisions of Legislative Decree 196/2003 and GDPR 2016/679.

The data are requested for the purpose of enrolment in online and offline courses such as SBA, Beauty Coach, Tailor Made, Tailor Made Forum, Demo, Refresh, Open Day, Renlive Academy.

This information concerns the personal data sent by the user when filling in the questionnaire.

Data Controller
The Data Controller of the data collected is Keekaz LLC Vat ID 85-2588057 with legal headquarters in 12400 Ventura Blvd 91604 Studio City (EE) United States Data Controller’s email address: info@sondelliguitars.com.

Data Processor
Google Ireland Limited (“Google”), a company incorporated and operating under the laws of Ireland (Registration number: 368047), with registered office at Gordon House, Barrow Street, Dublin 4, Ireland is appointed EXTERNAL PROCESSOR with respect to the processing carried out by him (cloud data management for Google Forms and associated services), pursuant to Articles 4 and 28 of the European Regulation 679/2016 and the data protection regulations.
As described in the Privacy Shield certification, Google complies with both the regulations relating to the EU-US Privacy Shield and concerning the Swiss-US Privacy Shield, as set out by the US Department of Commerce in relation to the collection, use and retention of personal information applicable to EU member countries and Switzerland respectively.
Google is responsible for any personal information provided to third parties for external processing on its behalf under the Onward Transfer Principle, as described in the section on sharing user information.
For more information about the Privacy Shield program and to view Google’s certification, please visit the Privacy Shield website.
More information on how Google processes data can be found at this link:
https://policies.google.com/privacy/update

Types of data processed and purposes
The data processed include: email address, company name, first name, surname, address, telephone number, VAT number, payment method and related notes (therefore falling within the so-called special categories of personal data, for which consent is required, pursuant to Art. 9 GDPR).
The purposes of the processing of your data are as follows:
The data sent will be used for the purpose of enrolment in online and offline courses such as SBA, Beauty Coach, Tailor Made, Tailor Made Forum, Demo, Refresh, Open Day, Renlive Academy.

Types of data processed and purposes
The Google service includes a suite of applications linked to the Gmail mail account, including Google Cloud Platform (document repository and storage on the cloud), Documents, Sheets, Forms and other applications of Google and its partners that you use to create, store and manage documents and attachments.

Access to data
Communications intended directly or indirectly for the Data Controller are handled by Google’s servers.
The protocols on which the information passes through the network and data is stored is the HTTPS protocol (HyperText Transfer Protocol over SSL), a variant of the HTTP protocol that uses, in addition to TCP/IP, the SSL (Secure Sockets Layer) which encrypts incoming and outgoing data using a mathematical algorithm.
The owner accesses the Google account through the use of passwords and two-step authentication.
We would like to inform you that the data you voluntarily provide via the questionnaire will be converted into an email that may be stored in the email reception system used by the site owner.
This data will not be recorded on other media or devices, nor will other data resulting from your navigation on the site be recorded.

Data location
List of Google data centre locations:
https://www.google.com/about/datacenters/inside/locations/index.html

Duration of data
The data in the form are stored for a maximum of two years, after which time they may no longer be representative and useful for a correct analysis of the data subject’s situation.

Consequences of not recording data
There is no obligation to provide the operator of this site with the personal data requested in the questionnaire.
The provision of data via the contact form is optional.
However, refusal to provide data for the purposes indicated above will make it impossible to contact the manager of the website via the form made available on the Site and consequently prevent the Owner from proceeding with the registration of online and offline courses such as SBA, Beauty Coach, Tailor Made, Tailor Made Forum, Demo, Refresh, Open Day, Renlive Academy.

Cookies Policy

In order to make its services as efficient and simple to use as possible, this website uses cookies. Therefore, when you visit the website, a minimum amount of information is entered into the User’s device, such as small text files called “cookies”, which are saved in the User’s web browser directory.

There are different types of cookies, but basically the main purpose of a cookie is to make the website work more effectively and to enable certain features.

Cookies are used to improve the User’s global navigation.

Here are the cookies we use:

[render_cookies_list]

More specifically:
They allow you to efficiently navigate from one page of the website to another.
They memorize the username and preferences entered.
They allow you to avoid entering the same information (such as username and password) several times during the visit.
They measure the use of services by Users, to optimize the browsing experience and the services themselves.
They present targeted advertising information based on the interests and behavior expressed by the User while browsing.
There are various types of cookies.

Below are the types of cookies that can be used on the site with a description of the purpose linked to their use.

Technical cookies

Cookies of this type are necessary for the proper functioning of some areas of the site. Cookies in this category include both persistent cookies and session cookies. In the absence of these cookies, the site or some portions of it may not work properly. Therefore, they are always used, regardless of the user’s preferences. Cookies in this category are always sent from our domain.

Analytical cookies

Cookies of this type are used to collect information on the use of the site. The Owner uses this information for statistical analysis, to improve the site and simplify its use, as well as to monitor its correct functioning. This type of cookie collects anonymous information on user activity on the site and on how they arrived at the site and the pages visited. Cookies in this category are sent from the site itself or from third-party domains.
Third party tracking cookies

Cookies of this type are used to collect information on the use of the website by visitors, the keywords used to reach the site, the websites visited and the origins of the traffic from which visitors come for marketing campaigns. The owner can use this information to compile reports and improve the Site. The cookies collect information anonymously. Cookies of this type are sent from the site itself or from third-party domains.

Cookies for the integration of third-party functionality

Cookies of this type are used to integrate third-party functionality on the site (for example, forms for comments or social network icons that allow visitors to share the content of the site). Cookies in this category can be sent from the domains of partner sites or that in any case offer the features present on the site.
The Owner is not required to request the user’s consent for technical cookies, as these are strictly necessary for the provision of the service.

For other types of cookies, consent can be expressed by the User, in accordance with current legislation, through specific configurations of the browser and computer programs or devices that are easy and clear to use for the User. The Owner reminds the User that it is possible to change the cookie preferences at any time. It is also possible to disable cookies from the browser at any time, but this operation may prevent the User from using certain parts of the Site.


Third party websites and cookies

The site contains links to other websites that have their own privacy policy. These privacy policies may be different from the one adopted by the Owner, who therefore is not liable for third-party sites.
Pursuant to art. 122 second paragraph of the Legislative Decree 196/2003 the consent to the use of these cookies is expressed by the interested party through the individual setting that he has freely chosen for the browser used to navigate the site, without prejudice to the User’s right to communicate at any time to the Data Controller their will regarding data managed through cookies that the browser itself has accepted.

By visiting a website you may receive cookies from both the visited site (“owners”) and from sites managed by other organizations (“third parties”). A notable example is the presence of “social plugins” for Facebook, Twitter, Google+ and LinkedIn. These are parts of the visited page generated directly by the aforementioned sites and integrated into the host site page. The most common use of social plugins is aimed at sharing content on social networks.

The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by “third parties” is governed by the relevant information to which reference should be made. To ensure greater transparency and convenience, the web addresses of the various information and methods for managing cookies are shown below.

Google Analytics

The site also includes certain components transmitted by Google Analytics, a web traffic analysis service provided by Google, Inc. (“Google”). Also in this case these are third-party cookies collected and managed anonymously to monitor and improve the performance of the host site (performance cookies).

Google Analytics uses “cookies” to anonymously collect and analyze information on site usage behavior (including the user’s IP address). This information is collected by Google Analytics, which processes it in order to draw up reports for the site managers regarding the activities on the website themselves. This site does not use (and does not allow third parties to use) the Google analysis tool to monitor or collect personal identification information. Google does not associate the IP address with any other data held by Google nor does it try to connect an IP address with the identity of a user. Google may also communicate this information to third parties where this is required by law or where such third parties process the aforementioned information on behalf of Google.

For further information, please refer to this link: https://www.google.it/policies/privacy/partners/

The user can selectively disable the action of Google Analytics by installing the opt-out component provided by Google on their browser. To disable the action of Google Analytics, please refer to this link: https://tools.google.com/dlpage/gaoptout

Duration of cookies

Some cookies (session cookies) remain active only until the browser is closed or the logout command is executed. Other cookies “survive” when the browser is closed and are also available on subsequent visits by the user.

These cookies are called persistent and their duration is set by the server at the time of their creation. In some cases a deadline is set, in other cases the duration is unlimited.

Cookie management

The user can decide whether or not to accept cookies using the settings on their browser.

Please note: the total or partial disabling of technical cookies can compromise the use of the site features reserved for registered users. On the contrary, the usability of public content is also possible by completely disabling cookies.

Disabling “third party” cookies does not affect navigability in any way.

The setting can be defined specifically for the different websites and web applications. Furthermore, the best browsers allow you to define different settings for “proprietary” and “third party” cookies.

By way of example, in Firefox, through the Tools-> Options -> Privacy menu, you can access a control panel where you can define whether or not to accept the different types of cookies and proceed with their removal.