Hereinafter the above-mentioned web portal including all assimilated services will also be collectively referred to as ‘Website’ or ‘Site’.
Polato Consulting abides by the EU Principles which are contained in the Reg. UE n. 2016/679 together with all other applicable laws (including, where relevant, international laws – AU Privacy Act 1988 (Cth) – US Privacy Act 1974, as amended, 5 U.S.C. § 552a ) relating to privacy.
If the user is under the age of 14 years old, following article 8, c. EU regulation 2016/679, he/she must legitimize his/her consent through the authorization of the parents or whoever takes their place.
The data controller is the physical or legal person, public authority, service, or other body that, individually or together with others, determines the purposes and means of processing personal data.
Concerning this Website, the owner and controller is
Polato Consulting, with registered office on Office 1110, International Business Tower, Business Bay, Dubai, UAE
and for any clarification or exercise of the rights of the user, you can contact our staff at the following email address: email@example.com.
The processing of data generated by the use of the website takes place in Italy.
Personal Data We Receive from You
Depending on how you use our Website, you will be subject to different types of Personal Data collected and different manners of collection.
Personal Data is defined in Reg. UE n. 2016/679 as well in the US Privacy Act as including ‘any information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.’
Using the Site, we will collect some of the following Personal Data from you through your voluntary disclosure:
- Identifying Information. For example, we may collect your name, unique personal identifier, online identifier, mailing address, email address, postal address, and telephone number, including your mobile phone number.
- Payment Information. For example, we may collect your credit card number and billing address.
- Information You Post. For example, we may collect the information you post in a public space on our site. This may include our Ratings & Reviews feature.
- Event Information. For example, we may collect the mailing address associated with your event registry.
- Information You Submit. For example, we may collect information when you contact us through any contact form or “live chat” feature on our site. We may also collect information submitted in connection with creating an account, completing an application, placing an order, or making a purchase, including bank account numbers, or other financial information.
- Demographic Information. For example, we may collect your age, gender, and zip code.
- Driver’s License Information or ID Information. To the extent permitted by applicable law, we may collect your driver’s license or ID information. For example, we may collect this information if you return an item without a receipt.
- Commercial Information. For example, we may collect information about the products or services purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.
By undergoing the purchasing process, you consent to us collecting your Personal Data, including the Personal Data described in this Policy or all those that will be required, as well as storing, using, or disclosing your Personal Data, for users from European countries, according to GDPR UE 2016/679.
The user is invited to don’t provide any information (in particular related to health), own or belonging to third parties, constituting particular data according to art. 9 GDPR 679/2016 without written consent.
Personal Data We Receive Automatically
We may collect information from you through automatic tracking systems (such as information about your preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Site, as described above).
A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not an executable code and does not transmit viruses.
It is important to state that Cookies do not record or store any Personal Data.
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Technical cookies
Technical cookies are used for navigation and to facilitate your access to and use of the Website. Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Website. These are also considered technical cookies when they operate as described.
- Third-party cookies
We may also utilize third-party cookies, which are cookies sent by a third-party to your device. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests, and then customize advertising for users.
Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the Application. Third-party analytical cookies are used to detect information on user behavior on our Website.
This place anonymously, to monitor the performance and improve the usability of the Site. Third-party profiling cookies are used to create profiles relating to users, to propose advertising in line with the choices expressed by the users themselves.
- Profiling cookies
We may also use profiling cookies, which are those that create profiles related to the user and are used to send advertising to the user’s device.
- Essential cookies
We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.
For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, following applicable laws, to block attempts at damage to the Site or damage to other users, or in the case of harmful activities or crime.
Such data are never used for the identification or profiling of the user, but only for the protection of the Website and our users.
Such information will be treated according to the legitimate interests of the Data Controller.
What are Your choices regarding cookies?
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our services might not display properly.
So, you can manage or request the general deactivation or cancelation of cookies through your device or browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the Site.
We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help us with our Website, and to help serve you.
In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.
Interaction with Social Network
All social networks (or similar services) are to be considered as external parties not bound by this document.
All buttons, badges, links, or similar related to social networks are to be considered, according to the Privacy Act, out of Polato Consulting’s competence.
How Personal Data is Stored
We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.
Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.
Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancelation of your account or other general requests for the deletion of data.
All the material related to this document is stored on Aruba spa’s servers, exclusively for the time necessary to provide the requested service and in any case in compliance with the current legislation.
Purpose Of Processing Personal Data
We primarily use your Personal Data to help us provide a better experience for you on our Site and to provide you the services and/or information you may have requested.
Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts.
Examples of how we may use your information include:
- To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or return transactions.
- To Improve Our Products and Services. We may use your information to make our Platforms and stores better. We may also use your information to customize your experience with us.
- To Understand Your Interests. For example, we may use your information to better understand what products interest you based on the information we collect about you and your household.
- To Respond to Your Requests or Questions. This may include responding to your customer feedback.
- For Security Purposes. This could include protecting our company and our customers. It may also include protecting our Platforms.
- For Marketing Purposes. We may provide you with information about new products and special offers. We may use your information to serve you ads about products and offers. We may tell you about new features or updates. These might be third-party offers or products we think you might find interesting. For more information about your choices related to these communications, see the Choices section below.
- To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.
- As Otherwise Permitted By Law or As We May Notify You.
In assessing the appropriate level of security, we shall take account in particular of the risks that are presented by Processing, in particular from a Personal Data Breach.
We shall notify User without undue delay upon becoming aware of a Personal Data Breach affecting User Personal Data, providing User with sufficient information to allow the Company to meet any obligations to report or inform Data Subjects of the Personal Data Breach under the Data Protection Laws.
We do not share, sell, lend or lease any of the Personal Information that uniquely identify a subscriber (such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.
Disclosure of Personal Data
Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:
- a) To satisfy any Local, State, or Federal laws or regulations
- b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies
- d) As may be necessary for the operation of our Site
- e) To generally cooperate with any lawful investigation about our users
- f) If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules.
According to US overall legislation, and in full respect for EU users to Regulation (EU) 2016/679, the User has many rights concerning Personal Data.
Specifically, User rights are as follows:
– The right to be informed about the processing of Personal Data
– The right to have access to Personal Data
– The right to update and/or correct Personal Data
– The right to portability of Personal Data
– The right to oppose or limit the processing of Personal Data
– The right to request that Company stop processing and delete User Personal Data
– The right to block any Personal Data processing in violation of any applicable law
– The right to launch a complaint with the data protection authority
Acceptance of Risk
Opting Out of Transmittals From Us
From time to time, we may send you informational or marketing communications related to our Sites such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
You may also click the opt-out link which will be provided at the bottom of all such communications.
Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Website or your account with us.
By providing any Personal Data to us, or by using our Site in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from Us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.
Special Note About Children
Children are not eligible to use our services unsupervised and we ask that children (under the age of 14) do not submit any Personal Information to us. If you are a minor, you can use this service only in conjunction with permission and guidance from your parents or guardians.