Privacy Policy

Introduction

cvottimo (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your Personal Data (as defined below).

This Privacy Policy (“Privacy Policy”) aims to give you (the “User(s)” or “you”) information on how we collect, store, use, and/or share and otherwise process, in our capacity as data controller the Personal Data we may collect relating to you when you use our services (the “Services”), such as when you:

visit our website https://cvottimo.com/privacy-policy or any other website which displays this Privacy Policy (the “Site(s));
Create a user account on the Site and as part of the use of its Services,
Fill in one of our contact forms or contact us by any other means (e-mail, telephone, social networks etc.);
Pay for your subscription;
Engage with us in other related ways, including any sales, marketing or events.

This Privacy Policy has been drafted in light of the General Data Protection Regulation (“GDPR”) and the Data Protection Act no. 78-17 of 6 January 1978 as amended and related CNIL standards and recommendations (the “Applicable law”). We are committed to follow the GDPR in all data processing operations in the European Economic Area and where it otherwise applies.

Our Site and our Services are not intended for children and we do not knowingly collect data relating to children. If you think that your child provided this kind of information on our Site, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

It is important that you read this Privacy Policy together with any other Privacy Policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

1. Important information and who we are

Controller

cvottimo company name is the controller and responsible for your Personal Data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details

Email address: data@ cvottimo .com
Postal address: company name

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. This version was last updated on 1rst of June 2024

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective on the Site as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your Personal Data.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

2. The data we collect about you

“Personal Data” means any information that may be used, alone or in combination with other information, to identify you. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data: includes billing address, delivery address, email address and telephone numbers.
Career Data: includes employment history and education history, included education establishments attended, years attended and qualifications gained.
Financial Data: includes the cardholder's name and bank card number, the expiry date, the visual cryptogram, the transaction number and details, the date and amount of the transaction. It is specified that the Company does not have access to these bank details and does not store them. This data is collected by our payment management provider ;
Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data : includes information collected by way of log files, namely internet protocol (IP) address, browser type and version, Internet Service Provider (ISP), date and time stamp, referring/exit pages, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data: includes information about how you use our Site, products and services.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We also collect, use and share agWe do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.gregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your Personal Data collected?

We use different methods to collect Personal Data including through:

a) Direct interactions. You may give us your Identity, Contact, Career and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

apply for our Services and/or answer or specific requests for information so that we may provide the requested Services to you;
create an account on our Site;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

b) Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies (for further information on our use of cookies see the relevant section below).

3. How we use your personal data

We will only use your Personal Data when the Applicable law allows us to. Most commonly, we will use your Personal Data in the following circumstances (with further information about each possible basis of processing provided below):

a) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

b) Where we need to comply with a legal obligation. Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

c) Where we need to perform the contract we are about to enter into or have entered into with you. Performance of contract means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

d) Your consent. Generally, we do not rely on consent as a legal basis for processing your Personal Data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact (c) Career	Performance of a contract with you
To process your request for Services and provision of those Services, including managing payments, fees and charges, and collecting and recovering money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To allow you to exercise your rights in application of the GDPR or other legal or regulatory provisions in force	(a) Identity (b) Contact (c) Content of our communications for the purpose of dealing with your request	Necessary to comply with a legal obligation

4. Cookie

During your browsing on the Site, cookies may be placed on your terminal (computer, mobile, tablet), subject to the choices you have made and which you may modify at any time.

These cookies are managed by the User's web browser.

To find out more about cookies and their impact, please consult the "How it works" section of the CNIL website, which can be accessed here.

1. What is a cookie?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. Our Site uses cookies to distinguish you from other users of our Site. This helps us provide you with a good experience when you browse our Site and also allows us to improve our Site.

A cookie will typically contain a record of the website which issued it, its own name, and a value which is often a randomly generated unique number.

There are several categories of cookies:

Technical cookies: these cookies are purely technical, are not intended for profiling and are strictly necessary for the provision of the service of consulting the resources available on your online media library. They enable and/or facilitate electronic communication. Under no circumstances do we use or disclose your information for advertising or commercial purposes. These cookies do not require consent: session cookies and navigation assistance cookies;
Preference cookies: these enable a website to remember information that modifies the way the site behaves or is displayed, such as your preferred language or the region in which you are located;
Marketing cookies: these are used to track visitors through websites. The aim is to display advertising that is relevant and interesting to the individual user and therefore more valuable to third-party publishers and advertisers;
Statistics cookies: These cookies are used to improve the quality of our services and enable us to track site traffic;
Unclassified cookies: these are cookies that are in the process of being classified, as well as individual cookie suppliers.

The following cookies are used on the Site:

Type of cookie	Name of the cookie	Type of cookie	Who manages them?	Function	Duration
Strictly necessary cookies	XSRF-TOKEN	HTTP	Data controller	Ensures the security of visitors' browsing by preventing the falsification of requests between sites. This cookie is essential for the security of the website and the visitor.	1 day
Strictly necessary cookies	CookieConsent	HTTP	Cookiebot	Stores the user's permission to use cookies for the current domain	1 year
Strictly necessary cookies	1.gif	Pixel	Cookiebot	Used to count the number of sessions on the website, necessary to optimise the delivery of CMP products.	Session
Strictly necessary cookies	test_cookie	HTTP	Google	Pending	1 day
Strictly necessary cookies	rc::a	HTML	Google	This cookie is used to distinguish humans from robots. This is beneficial to the website in order to create valid reports on the use of their site.	Session
Strictly necessary cookies	rc::c	HTTP	Google	This cookie is used to distinguish humans from robots.	Session
Marketing cookies	lastExternalReferrer	HTML	Meta Platforms, Inc.	Detects how the user reached the website by recording their last URL address.	Persistent
Marketing cookies	lastExternalReferrerTime	HTML	Meta Platforms, Inc.	Detects how the user reached the website by recording their last URL address.	Persistent
Marketing cookies	_fbp	HTTP	Meta Platforms, Inc.	Used by Facebook to provide a range of advertising products such as real-time offers from third-party advertisers.	3 months
Marketing cookies	pagead/landing	Pixel	Google	Collects data on visitor behaviour from several websites in order to present more relevant advertising. This also allows the website to limit the number of times the same advertisement is shown to the visitor.	Session
Marketing cookies	_ga	HTTP	Google	Used to send data to Google Analytics about the visitor's device and behaviour. Follows the visitor across devices and marketing channels.	2 years
Marketing cookies	_ga_#	HTTP	Google	Used to send data to Google Analytics about the visitor's device and behaviour. Follows the visitor across devices and marketing channels.	2 years
Marketing cookies	_gcl_au	HTTP	Google	Used by Google AdSense to test the effectiveness of advertising on various websites using their services.	3 months
Marketing cookies	ads/ga-audiences	Pixel	Google	Used by Google AdWords to re-engage visitors who are likely to convert into customers on the basis of their online behaviour on websites.	Session
Other	cvottimo_session	HTTP	Data controller	Pending	1 day

With the exception of strictly necessary cookies, which are constantly active, the User may refuse cookies by activating the cookie settings via a dedicated screen. If the User does not wish to consent to the use of cookies by the Company, the User may refuse cookies and/or refuse access to previously stored information by using his/her web browser.

The web browser functions that enable the User to do this vary from one browser to another. If cookies are disabled, the User may not be able to use all of the interactive features of the Site and this may limit the service that the Company is able to provide via the Site.

As mentioned above, the Sites uses Google Analytics, an analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to personalize ads, and for advertising purposes (personalized ads or not). We employ Google Signals on our Site, enabling Google Analytics to link session data collected from our site and apps with Google's information from signed-in, consented users. You retain the right to access and delete any such data through Google's My Activity feature.

For more information about how Google uses your Personal Data, please see here.

The information generated by the cookie about your use of the Site(s) (including your IP address) will be transmitted to Google in the USA.

You may prevent Google from collecting and using data (cookies and IP address) by downloading and installing the browser plug-in here.

Follow these links for further information concerning the terms and conditions of our use of Google analytics External reference, the information that Google provide on data privacy and security, and Google’s data privacy notice.

2. How long is the information stored on your browser kept?

The information stored on the User's browser used to identify the User and to enable traceability, as well as the raw data on the User's use of the Site associated with an identifier, will only be kept by us for a maximum period of thirteen (13) months. After this period, the data is either deleted or made anonymous.

3. How do I accept or reject cookies on my browser?

It is possible to configure your browser so that cookies are stored in the terminal or rejected, either systematically or according to the sender, or so that you are informed when a cookie is stored in the terminal, allowing you to accept or reject it.

However, deleting all cookies used by the browser, including those used by other websites, may lead to the alteration or loss of certain settings or information.

The configuration of each browser is different. It is your responsibility to follow the instructions of your browser's publisher as follows (links available at the time of updating this page):

If you use Internet Explorer: link
If you use Firefox: link
If you use Safari: link
If you use Chrome: link

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

5. Recipients of Personal Data

Your Personal Data will only be disclosed to the following recipients or categories of recipients, within the limits of their respective responsibilities and insofar as such disclosure is strictly necessary to achieve the purposes set out in this Privacy Policy:

Authorized employees or workers of the Company that have a need for such access for the purpose for which it was collected.
Service providers. We may need to disclosure Personal Data to companies that provide services to us linked to our Services that is necessary which are not permitted to use your Personal Data for any other purpose than to carry out the services they are performing for us;
Third parties, where required by law: We may disclose Personal Data to a third party if we are under a legal duty to do so in order to comply with any legal obligation or any decision of a judicial authority, a public authority or a government body, or if disclosure is necessary for national security, law enforcement or other issues of important public interest.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. International Transfers

Before transferring your Personal Data outside the European Union, we will take steps to ensure that such data will be afforded the same level of protection as under applicable data protection laws within the European Union. For data transfers outside of the European Union, we use applicable safeguards, including the standard contractual clauses adopted by the European Commission and will make available a copy to you upon request.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the European Union.

7. Data Security

We have put in place appropriate security measures, including encryption, to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot guarantee the security of your Personal Data transmitted to us using unsecured means. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Data Retention

How long will you use my Personal Data for?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for as set out in this Privacy Policy. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or any other situation when required or permitted by the law.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In particular, we apply the following retention periods for these few main categories of Personal Data:

For Identification Data,

when you create an account, we keep your Personal Data for as long as your account is active;
when you do not create an account:

7 days when you use the Services anonymously (i.e. when your email address has not been provided)
30 days when you have never been active since the creation of your account;
90 days when your subscription has expired.

For Financial Data, the data is kept until the last payment due date of the subscription.

In some circumstances you can ask us to delete your data (see below for further information).

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

In accordance with the Applicable Law, you have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data that we hold about you and to check that we are lawfully processing it.
Request rectification of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new Personal Data that you provide to us.
Request erasure of your Personal Data. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Request restriction of processing of your Personal data.
Request portability of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Direct how your Personal Data should be used after your death.

If you wish to exercise any of your above rights, please send a written request to our data privacy manager whose contact details listed above. You will not have to pay a fee to access your Personal Data or to exercise any of your other rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You can exercise these rights by contacting us by using the contact details provided in the section “Contact Details” above.

10. Complaints

If you believe we are unlawfully processing your Personal Data, you also have the right to file a complaint with the CNIL (https://www.cnil.fr/).