Welcome to the SNATCH Privacy Center.
Welcome to the SNATCH Privacy Center.
Below are some questions about the data we collect and to which we can give immediate response.
What information does SNATCH collect?
How does SNATCH use the information collected?
We use the information collected to update the data in our possession, offer and improve our offer and service to customers. For example, we use your information to create your account, offer our services within the website and / or mobile applications), and to identify and prevent fraud and abuse.
Are the data shared with third parties?
The translated versions of contracts and legal policies are provided only in order to facilitate reading and understanding of the Italian versions. The provision of translations of contracts and legal policies does not have as its objective to create a binding contract at the legal level, nor to replace the legal validity of the Italian versions
SNATCH collects some Personal Data from its Users.
Owner and Data Controller
Marco Guastaldi -Via Cavour, 42 - 21100 Varese (VA) Italy
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that SNATCH collects, by itself or through third parties, there are: Cookies, Usage Data, email address, first name, last name, date of birth, various types of Data, phone number, country, province, website, field of activity, city and password.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using SNATCH.
Unless specified otherwise, all Data requested by SNATCH is mandatory and failure to provide this Data may make it impossible for SNATCH to provide its services. In cases where SNATCH 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.
Users are responsible for any third-party Personal Data obtained, published or shared through SNATCH and confirm that they have the third party’s consent to provide the Data to the Owner.
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 SNATCH (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.
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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
· 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.
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.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or 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.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
· 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 do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to 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 purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Registration and authentication, Remarketing and behavioral targeting, Managing support and contact requests, Content performance and features testing (A/B testing), Contacting the User, Social features, User database management, Handling payments, Tag Management, Heat mapping and session recording, Hosting and backend infrastructure, Interaction with online survey platforms, Interaction with data collection platforms and other third parties, Infrastructure monitoring and Managing contacts and sending messages.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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.
Contacting the User
Mailing list or newsletter (SNATCH)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning SNATCH. Your email address might also be added to this list as a result of signing up to SNATCH or after making a purchase.
Personal Data collected: date of birth, email address, first name and last name.
Payment processing services enable SNATCH to process payments by credit card, bank transfer or other means. To ensure greater security, SNATCH shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable SNATCH to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of SNATCH. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
This type of service allows SNATCH to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of SNATCH.
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of SNATCH for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Managing support and contact requests
This type of service allows SNATCH to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Registration and authentication
By registering or authenticating, Users allow SNATCH to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, SNATCH will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (SNATCH)
The User registers by filling out the registration form and providing the Personal Data directly to SNATCH.
Personal Data collected: date of birth, email address, first name, last name and password.
Remarketing and behavioral targeting
This type of service allows SNATCH and its partners to inform, optimize and serve advertising based on past use of SNATCH by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of SNATCH with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
This type of service helps the Owner to manage the tags or scripts needed on SNATCH in a centralized fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to SNATCH, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving SNATCH.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on SNATCH.
Further information about Personal Data
SNATCH may send push notifications to the User.
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by SNATCH depends on the payment system used.
Unique device identification
SNATCH may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through SNATCH to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
· 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. Further details are provided in the dedicated section below.
· 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, under certain circumstances, 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, under certain circumstances, 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. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
· Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
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 without providing any justification. 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. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
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 SNATCH 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
System logs and maintenance
For operation and maintenance purposes, SNATCH and any third-party services may collect files that record interaction with SNATCH(System logs) 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.
How “Do Not Track” requests are handled
SNATCH does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
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)
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.
Information collected automatically through SNATCH (or third-party services employed in SNATCH), which can include: the IP addresses or domain names of the computers utilized by the Users who use SNATCH, 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.
The individual using SNATCH who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
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 SNATCH. The Data Controller, unless otherwise specified, is the Owner of SNATCH.
SNATCH (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by SNATCH as described in the relative terms (if available) and on this site/application.
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.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Safe communication channels
We encrypt personal data that are provided to us via web forms using updated standards to prevent third parties from intercepting information in transit.
We require a unique username and identification method, such as a password to access your account.
Our employees receive annual training and periodic directives on good safety practices.
Security approach on several levels
We protect our company network using numerous levels of security:
1. – We use physical protection measures to ensure the safety of our employees and our equipment;
2. – We use a combination of software and devices to protect our networks from potential intruders;
3. – We have a dedicated team of security professionals who monitor the security practices of devices and applications.