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Privacy Policy
(Last revised: 20/06/2018)

Incomedia respects and attaches great importance to your privacy. This Privacy Policy is applicable to all websites and domains that are the property of Incomedia (“Incomedia Websites”) and it explains the measures that are adopted to safeguard your privacy pursuant to Art. 13 of Italian Legislative Decree 30.6.2003 no. 196 ("Privacy Code") and to Art. 13 of the EU Regulation no. 2016/679 ("GDPR"): in particular, it explains which personal information is collected and for what purpose, and how such information is treated and used.

Please read this Privacy Policy carefully before sharing any personal information with us. According to the terms of this Privacy Policy, the use of Incomedia Websites and Products implies agreeing to sharing personal information with Incomedia. If you do not agree with the terms of this Privacy Policy, please Do NOT use Incomedia Websites and Products.
If you have any questions about the terms of this Privacy Policy, please do not hesitate to contact us at  policy@incomedia.eu entering “Privacy” as the subject of your email.
1. Collecting personal information
Incomedia collects, exports and uses your personal information in order to better serve you and provide you with a more personal experience when interacting with us. However, your personal information will only be collected following appropriate notice and your explicit consent.
For example, when you order products or services, request information, subscribe to marketing or support documentation, or register yourself or Incomedia products online, you will need to supply personal information to complete the registration. Typical items of personal information that may be requested on these occasions include contact information (e.g. name, address, telephone number and email address), information such as user Ids and passwords, invoicing and transaction details, and product and service preferences.
If you publish, comment or share personal information, including photographs, on a forum, social network, blog or other similar forums of Incomedia, you do so under your own responsibility, in the knowledge that your personal information may be read, seen, collected or used by other users to make contact, send unrequested messages or for other purposes beyond your control or that of Incomedia. Incomedia cannot be held liable for the privacy and treatment of personal information that you choose to publish on said forums.

1.1 Registration
During the registration procedure, you may be asked to enter personal details such as your name, surname, email address, home address, and you may also be asked to choose a password. Incomedia sends every visitor and/or customer a welcome email, asking them to check that the email address provided is correct.
A valid email address is important because order confirmations, download links, access key codes and product and support information will be sent to this address. If the email address provided during registration results invalid, Incomedia may deactivate the associated password.

1.2 Purchases
If you purchase a product from an Incomedia Website, you will be asked for information related to contact details, invoicing and delivery. This information will be used  for processing the order, its payment and its delivery. Should any problem occur during the purchase transaction, a representative of Incomedia will contact you via email, telephone, fax or post in order to resolve it.
Please note that, during purchase transactions, Incomedia does not register any credit card numbers, and all essential information (credit card numbers, validation numbers, etc) are handled exclusively by PayPal (for further information on transaction security and relative Privacy Policy, please visit the PayPal website  at www.paypal.com).
Please note also that customers outside Italy who order Incomedia products online  from one of our international online stores can consult the Privacy Policy of the e-commerce platform supplier directly on the website (www.cleverbridge.com, www.digitalriver.com and www.pagbrasil.com).

1.3 Downloads
When you download a demo version or free software, you may be asked for personal information such as your email address. In such cases, the email address is used to send messages relating to the download procedure, such as download links, activation codes, technical support information and upgrades for the software in question.

1.4 Surveys and competitions
Incomedia may occasionally carry out surveys or run competitions for its users and, to do this, certain information may be required. Participation in such events is voluntary and the collected information will be treated according to the indications in the specific Privacy Policy for each one. In all cases, if the results of a survey or a competition should be published, personal information will not be disclosed without the explicit consent of the interested parties.

1.5 Mobile app
Incomedia's mobile app may require access to some of the device inner functionalities.
FeedReady
Access to the phonebook to share the URL of the webpage that has been seen. No data is sent to Incomedia.
Consent to send push notifications regarding the updates of the articles you have viewed.
WebSite X5 Manager
Access to the camera so to scan the QR Code. No data is sent to Incomedia.
Consent to send push notifications regarding the updates of the subscribed websites.
The user can deny the access of the Mobile App to the required functionalities through the settings of the device itself. For further information about push notifications please visit Apple and Google websites.

1.6 Data collected from sites, e-mail and apps
As well as specifically requested information, Incomedia may also employ commonly-used automatic data-collection tools to collect data during your visit to an Incomedia Website. These tools include cookies, web beacons and embedded links. These automatic tools collect standard traffic information that the browser sends to Incomedia Websites, such as the type and language of the browser, the access times and the address of the website from where you have arrived.
Automatically-collected information may also include your IP (Internet Protocol) address, clickstream behaviour (i.e. the number of pages visited, links opened and other actions that you may have taken in connection with Incomedia Websites) and product information.
Finally, Incomedia may use some of the above-mentioned automatic data-collection tools to analyse its applications and emails sent alike, in order to collect information, for example, about the use of the applications, on the number of times the messages are opened and the number of clicks on links contained in the messages.
For further information on automatic data-collection tools, see paragraph 6, Cookies and registration with websites.
2. How collected information is used
Incomedia uses collected information without your express consent (Art. 24 letters a), b), c) of the Privacy Code and Art. 6 letters b), e) of the GDPR) for various purposes, which include:
a. assistance in completing a transaction or an order
b. complying with the precontractual, contractual and fiscal obligations arised from the relationship with you
c. providing services and assistance
Incomedia uses collected information with your prior specific and distinct consent (Articles 23 and 130 of the Privacy Code and Art. 7 of the GDPR) for various purposes, which include:
a. sending news about products and services
b. providing customized promotional offers
c. soliciting your opinion or feedback and offering you opportunities to test softwares
d. researching and implementing product improvements and updates
e. enabling you to Refer-a-Friend who may be interested in our offers, as permitted by law
f. selecting content to show to you
g. measuring the performance of marketing initiatives, advertising and Incomedia Websites.
h. Making Remarketing Activity and Behavioral Targeting

The data transmission for the purposes mentioned on point 1 is compulsory. In the absence of such data, Incomedia will not be able to guarantee its services.
The data transmission for the purposes mentioned on point 2 is, on the other hand, elective. You can decide whether not to transmit any data or to later deny the possibility of processing the previously transmitted data: in this case, you will not receive any newsletter, commercial communication and advertising materials regarding the Services provided by Incomedia. You will still be entitled to the Services mentioned on point 1.

Incomedia may use collected personal information to contact you periodically to communicate important news about its Products, Services and/or Websites. If you specifically request so, Incomedia may also send you newsletters which may include special offers and/or other opportunities offered by partner companies that may be of interest to you.
You can choose which kind of communications you wish to receive from Incomedia, and you can cancel your subscription at any time through your online user profile.
You can also cancel subscriptions (Art. 130 clause 4 of the Privacy Code) by clicking on the relative link directly in the emails you receive. When you cancel a subscription, your email address will be promptly deleted from Incomedia's mailing list, usually prior to the next issue. No further commercial communications will be sent to your email address. If necessary, however, you will continue to receive service communications, for example that relate to on-going transactions.

3. Processing Method
The personal data processing method is realized according to the operations described on Art. 4 (Privacy Code) and Art. 2 (GDPR), namely:  data collection, elaboration, modification, selection, mining, comparison, usage, interconnection, block, communication, deletion and destruction.
Your personal data are processed in both printed and electronic/automated forms.
Incomedia will process all personal data for the necessary time to fulfill the above mentioned purposes, for example, to maintain ongoing business relationships, to provide the user with products, services or information they are entitled to, etc.

4. Disclosing collected personal information
Your data can be made available for the purposes mentioned in section 2 without the necessity of an express consent ( in pursuance of Art. 24 letters a), b), d) of the Privacy Code and Art. 6 letters b) and c) of the GDPR):
- to Incomedia employees and coworkers, in Italy and abroad, in their capacity as internal delegates and/or people in charge for the Personal Data and/or system administrators.
- to third-party companies or actors (including but not limited to credit institutions, professional firms, consultant etc.) engaged in oursourcing activities for Incomedia, in their capacity as external manager of the Personal Data.
Incomedia does not sell, rent, transfer or yield personal information on its users to third parties, except as indicated in this Privacy Policy or in compliance with current laws.
Incomedia may share some information with its partners for marketing or promotional purposes: in such cases, data is always and only provided in an aggregate form, making personal identification impossible.
Your profile and contributions to Incomedia Websites will be published and identifiable with the user name you have chosen. Under no circumstances will Incomedia share your email address or any other personal information with other users of the  Incomedia Website, and under no circumstances will Incomedia publish your email address or any other personal information without your prior explicit consent.

5. Links to other websites
Incomedia's Websites may contain links to third-party websites, for informative purposes. Incomedia has no control over external websites or over their privacy policies. For these reasons, this Privacy Policy does not cover, or apply to, external websites.
Incomedia invites you to read the specific privacy policies of websites and social media that you may access while visiting Incomedia Websites, and ensure that you fully understand how personal information is collected and treated by these websites.

6. Cookies and registration with websites
Cookies are small files that contain information sent by a web server to a web browser, and permit the server to collect information from the browser.
Incomedia and its service suppliers send cookies when you visit an Incomedia Website, or a website where Incomedia is advertised, and when you make a purchase, subscribe to services, or ask for further information.
Incomedia does not collect personal information through cookies, but only data that may facilitate your future logins, so that the Websites can keep a trace of the products you add to your shopping cart, the country you are operating from and the language and currency you use.
Cookies are also used to gather statistics on accesses to Incomedia Websites.
If you do not wish to receive cookies, you can block them or ask for prior warning before accepting them, according to the procedures followed by the web browser you are using on your computer. For more information on working with cookies in your browser, see Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer. However, if you decide to block the cookies, bear in mind that sometimes browsers react unexpectedly, not only when you visit Incomedia Websites but also when you visit other websites. Incomedia cannot identify users through the information collected by cookies, so we suggest that you accept them in order to able to make the most of the Websites.
For more information about the use of cookies and how to block them, visit www.allaboutcookies.org, www.youronlinechoices.eu (Europe) or www.aboutads.info/choices/ (United States).

7. Permission to use cookies
Current regulations require that a website informs visitors on how cookies are used in the website, and that this information is displayed in an instant banner on the first page of the website to be visited. The visitor can scroll the page and enable cookies by clicking on one of the links in the pages or clicking on the "OK" button in the banner.
8. Use of cookies in Incomedia websites

8.1 Technical cookies
I Siti Web di Incomedia utilizzano i seguenti cookie tecnici, che vengono installati automaticamente a seguito dell’accesso al sito, per le finalità indicate in relazione a ciascuno di essi:
Cookie di sessione necessaria al funzionamento e all'erogazione dei servizi del sito
Cookie di statistica utilizzati per raccogliere informazioni in forma aggregata.

8.2 Third-party cookies
Incomedia websites use the following third-party cookies:
Google AdWords
AdWords Remarketing is a Remarketing and Behavioral Targeting service provided by Google Inc. which links the activity of this application with the Adwords advertising network and the Doubleclick cookie.
Google Analytics
Facebook Remarketing
Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. which links the activity of this application with Facebook's advertising network.
Hellobar
MailChimp
Zendesk
Hotjar
Hotjar is a all-in-one Analysis and Feedback tool that reveals the online behaviour and feedback of a website's visitors.
If you do not expressly disable cookies, for example you close the cookie policy banner without reading the cookie policy or you continue to navigate the website, you actually express your consense to the use of all the mentioned cookies.

9. Access, update and edit of your personal information
You can modify and update the information you initially provided for subscription, by accessing your online user profile.
If you want to modify, correct, anonymize or delete your personal information, you can send an email to Incomedia's Customer Care service (policy@incomedia.eu) or send a letter to:
Incomedia S.r.l. – Customer Support
Via Burolo 22/A,
10015 Ivrea (TO) Italy

10. Protecting personal information
Incomedia adopts all the necessary physical, technical and administrative measures to avoid unauthorized access to and disclosure of personal information that it has collected from you, and to guarantee that this information is fully protected and correctly used. For example, only employees who have a legitimate reason may access this information, and we employ processes such as password hashing to protect the data from unauthorized access.
All online transactions involving credit cards are encrypted: Incomedia uses the Secure Socket Layer (SSL) protocol. Credit card numbers are not recorded, and during transactions, confidential data (credit card number, validation code, etc) is handled directly by PayPal, CleverBridge, DigitalRiver and PagBrasil (for further information, refer to www.paypal.com, www.cleverbridge.com, www.digitalriver.com and www.pagbrasil.com).
Incomedia uses certain subprocessors, subcontractors and content delivery networks (es: Service Data Storage, Mail Marketing, Payment Gateway, ecc) to assist it in providing the Incomedia Services. Incomedia requires its subprocessors to satisfy equivalent obligations as those required from Incomedia and in accordance with GDPR.
However, although we adopt the most stringent technical and organizational methods currently available to protect your personal information from unauthorized or illegitimate use, and from the loss, destruction or damage of your personal data, Incomedia cannot offer a 100% guarantee for personal information security.

11. Children's Privacy
Incomedia does not knowingly collect information on children under thirteen years old, and Incomedia's Websites are aimed at the public at large. If a child should send his or her personal information to Incomedia, and Incomedia is aware that this child is less than 13, the collected data will be used solely for the purpose of answering the child directly to inform him or her that parental/guardian consent is necessary for his or her action. Incomedia encourages parents and guardians to take an active role in supervising the online activities and interests of children.

12. Users Privacy Rights
Being the person concerned, you have the rights reported on Art. 7 of the Privacy Policy and Art. 15 of the GDPR, namely:
a) to ask to be provided with information regarding the Personal Data Incomedia processes concerning you;
b) to rectify, update or complement inaccurate or incomplete Personal Data concerning you;
c) to delete or request the erasure of Personal Data concerning you;
d) in certain circumstances to obtain that Incomedia restricts the way in which the company processes Personal Data concerning you;
e) to withdraw any consent you may have given to process Personal Data concerning you;
f) to object to our processing of Personal Data concerning you on the basis of third-parties’ legitimate interests;
g) to obtain the portability of Personal Data concerning you which Incomedia processed using automated means on the basis of your consent or of a contract you have entered into with Incomedia;
h) in the European Economic Area, to lodge a privacy complaint with a supervisory authority if you are unhappy with the way Incomedia has handled your Personal Data or any privacy query or request that you have raised with Incomedia.

13. Changes to the Privacy Terms
Incomedia reserves the right to change the Terms of Use at any time. The modified Terms of Use will be published on the Incomedia Websites with the new revision date so that you can view the changes. By continuing to access and use the Website after the publication date, you agree to ,and accept, the changes. Please check the Terms of Use periodically to review any changes.
Incomedia also reserves the right to discontinue or modify or update the Website and its Contents at any time and without notice. Incomedia reserves the right to restrict, refuse or interrupt a User's access to the Website or part of it, at any time and without notice, and with immediate effect, at its sole discretion and for any reason.

14. Language of the present document
Where Incomedia has provided you with a translation of the Italian language version of the Terms of Use, then you agree that the translation is provided for your convenience only and that the Italian language versions of the Terms of Use govern your relationship with Incomedia.
If there is any contradiction between what the Italian language version of the Terms of Use says and what a translation says, then the Italian language version shall take precedence.

15. Controller, supervisor and appointees
Controller of your Personal Data is :

Incomedia S.r.l.
Via Burolo 22/A,
10015 Ivrea (TO) Italy

The updated list of all Personal Data superivisors and appointees is guarded at the Controller's registered office.
Except where otherwise noted, content on this site is copyright by Incomedia S.r.l. All rights reserved. P.IVA 07514640015 - C.C.I.A.A. 52501/1998 - TO
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