This Website collects some Personal Data from its Users.
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Policy summary
Personal Data collected for the following purposes and using the following services:
- Analytics
- Google Analytics, Facebook Ads conversion tracking (Facebook pixel), HubSpot Analytics and Google Ads conversion trackingPersonal Data: Tracker; Usage Data
- Contacting the User
- Contact form and Mailing list or newsletterPersonal Data: email address; first name; last name
- Phone contactPersonal Data: phone number
- Displaying content from external platforms
- Google Fonts and Fonts.com Web FontsPersonal Data: Usage Data; various types of Data as specified in the privacy policy of the service
- Font AwesomePersonal Data: Usage Data
- Google Maps widgetPersonal Data: Tracker; Usage Data
- Handling payments
- PayPal and StripePersonal Data: various types of Data as specified in the privacy policy of the service
- Interaction with live chat platforms
- Facebook Messenger Customer ChatPersonal Data: Data communicated while using the service; Tracker; Usage Data
- Managing contacts and sending messages
- MailchimpPersonal Data: company name; country; email address; first name; last name; phone number
- Managing data collection and online surveys
- Facebook lead adsPersonal Data: city; company name; country; Data communicated while using the service; email address; first name; last name; phone number; physical address; state; ZIP/Postal code
- Platform services and hosting
- WordPress.comPersonal Data: billing address; email address; first name; last name; payment info; phone number; shipping address
- Registration and authentication provided directly by this Website
- Direct registrationPersonal Data: billing address; city; company name; country; email address; first name; last name; password; phone number; username; VAT Number; ZIP/Postal code
- Remarketing and behavioral targeting
- Google Ads Remarketing, Facebook Remarketing and Remarketing with Google AnalyticsPersonal Data: Tracker; Usage Data
- Facebook Custom AudiencePersonal Data: email address; Tracker
- User database management
- HubSpot CRMPersonal Data: email address; phone number; various types of Data as specified in the privacy policy of the service
- HubSpot Lead ManagementPersonal Data: various types of Data as specified in the privacy policy of the service
Further information about Personal Data
- Selling goods and services onlineThe 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 this Website depends on the payment system used.
Contact information
- Owner and Data Controller DAVAND MEDIA AGENCY – Cernatesti 361, Buzau, Romania Owner contact email: office@sota360.ro
Full policy
Owner and Data Controller
DAVAND MEDIA AGENCY – Cernatesti 361, Buzau, Romania
Owner contact email: office@sota360.ro
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; email address; phone number; username; password; VAT Number; company name; country; ZIP/Postal code; city; billing address; shipping address; payment info; physical address; state; Data communicated while using the service.
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, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website 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 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.
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.
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.
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.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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 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 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 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: Analytics, Contacting the User, User database management, Displaying content from external platforms, Remarketing and behavioral targeting, Handling payments, Registration and authentication provided directly by this Website, Platform services and hosting, Managing data collection and online surveys, Managing contacts and sending messages and Interaction with live chat platforms.
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:
- AnalyticsThe 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 (Google Ireland Limited)Google Analytics is a web analysis service provided by Google Ireland Limited (“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.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy.HubSpot Analytics (HubSpot, Inc.)HubSpot Analytics is an analytics service provided by HubSpot, Inc.Personal Data processed: Tracker; Usage Data.Place of processing: United States – Privacy Policy – Opt Out .Google Ads conversion tracking (Google Ireland Limited)Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy. - Contacting the UserContact 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: email address; first name; last name.Mailing list or newsletter (this Website)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 this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.Personal Data processed: email address; first name; last name.Phone contact (this Website)Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.Personal Data processed: phone number.
- Displaying content from external platformsThis 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 Ireland Limited)Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: Ireland – Privacy Policy.Font Awesome (Fonticons, Inc. )Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Usage Data.Place of processing: United States – Privacy Policy.Fonts.com Web Fonts (Monotype Imaging Inc.)Fonts.com Web Fonts is a typeface visualization service provided by Monotype Imaging Inc. that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.Google Maps widget (Google Ireland Limited)Google Maps is a maps visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy. - Handling paymentsUnless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.PayPal (PayPal Inc.)PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: See the PayPal privacy policy – Privacy Policy.Stripe (Stripe Inc)Stripe is a payment service provided by Stripe Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.
- Interaction with live chat platformsThis type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.
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. Moreover, live chat conversations may be logged.Facebook Messenger Customer Chat (Facebook Ireland Ltd)The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook Ireland LtdPersonal Data processed: Data communicated while using the service; Tracker; Usage Data.Place of processing: Ireland – Privacy Policy. - Managing contacts and sending messagesThis 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.Mailchimp (The Rocket Science Group LLC)Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.Personal Data processed: company name; country; email address; first name; last name; phone number.Place of processing: United States – Privacy Policy. - Managing data collection and online surveysThis type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.Facebook lead ads (Facebook Ireland Ltd)Facebook lead ads is an advertising and data collection service provided by Facebook Ireland Ltd that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information. Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided. Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.Personal Data processed: city; company name; country; Data communicated while using the service; email address; first name; last name; phone number; physical address; state; ZIP/Postal code.Place of processing: Ireland – Privacy Policy – Opt out. - Platform services and hostingThese services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.WordPress.com (Aut O’Mattic A8C Ireland Ltd.)WordPress.com is a platform provided by Aut O’Mattic A8C Ireland Ltd. that allows the Owner to build, run and host this Website.Personal Data processed: billing address; email address; first name; last name; payment info; phone number; shipping address.Place of processing: Ireland – Privacy Policy. - Registration and authentication provided directly by this WebsiteBy registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.Direct registration (this Website)The User registers by filling out the registration form and providing the Personal Data directly to this Website.Personal Data processed: billing address; city; company name; country; email address; first name; last name; password; phone number; username; VAT Number; ZIP/Postal code.
- Remarketing and behavioral targetingThis 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.Google Ads Remarketing (Google Ireland Limited)Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.Facebook Remarketing (Facebook Ireland Ltd)Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Website with the Facebook advertising network.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.Facebook Custom Audience (Facebook Ireland Ltd)Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Website with the Facebook advertising network. Users can opt out of Facebook’s use of cookies for ads personalization by visiting this opt-out page.Personal Data processed: email address; Tracker.Place of processing: Ireland – Privacy Policy – Opt Out.Remarketing with Google Analytics (Google Ireland Limited)Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.Personal Data processed: Tracker; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out. - User database managementThis 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 this Website, 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 this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.HubSpot CRM (HubSpot, Inc.)HubSpot CRM is a User database management service provided by HubSpot, Inc.Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.HubSpot Lead Management (HubSpot, Inc.)HubSpot Lead Management is a User database management service provided by HubSpot, Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.
Further information about Personal Data
- Selling goods and services onlineThe 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 this Website depends on the payment system used.
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
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) 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
This Website 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.
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)
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.
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 Data Supervisor)
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.
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, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.