Privacy Policy

Creative Words Privacy Policy

This Website collects certain Personal Data from its Users.

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Data Controller

Creative Words s.r.l.
Via Cairoli 1/4 – 16124 Genoa (GE) – Italy

Holder’s email address: info@creative-words.com

Types of Data Collected

Among the Personal Data collected by this Website, either independently or through third parties, are: Usage data; Tracking tools; first name; last name; phone number; company name; email address; various types of data; number of Users; session statistics; data communicated while using the service; IP address; answers to questions; clicks; keypress events; motion sensor activity; mouse movements; scroll position; touch events; job position.

Detailed information on each type of Personal Data collected is provided in the specific sections of this privacy policy or through dedicated explanatory texts displayed before the Data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.
Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to provide it, the Website may be unable to provide the Service. Where this Website explicitly states that certain Data is optional, Users are free to withhold such Data without affecting the availability or functionality of the Service.
Users unsure about which Personal Data is mandatory are welcome to contact the Data Controller.
The use of Cookies – or other tracking tools – by this Website or by third-party service providers used by this Website is intended to provide the Service requested by the User, as well as the additional purposes described in this document.

The User is responsible for any third-party Personal Data obtained, published, or shared through this Website.

Methods and Location of Data Processing

Processing Methods

The Data Controller implements appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data.
Data processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the stated purposes. In some cases, other parties involved in the operation of this Website (administrative, sales, marketing, legal, system administration personnel) or external entities (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) may also have access to the Data and, if necessary, be appointed as Data Processors by the Data Controller. An up-to-date list of such parties may be requested from the Data Controller at any time.

Location

Data is processed at the Data Controller’s operational offices and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. For further details about the location of processing, Users may refer to the section on details of Personal Data processing.

Data Retention Period

Unless otherwise stated in this document, Personal Data is processed and stored for as long as required by the purpose for which it was collected, and may be retained for a longer period due to legal obligations or based on the User’s consent.

Purpose of Data Processing

User Data is collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of its Users or third parties), detect malicious or fraudulent activity, and for the following purposes: Displaying content from external platforms, Analytics, Contacting the User, Managing contacts and sending messages, User database management, Tag management, Traffic optimization and distribution, and SPAM protection.

For detailed information about the purposes of processing and the specific Personal Data used for each purpose, Users may refer to the section “Details on the Processing of Personal Data.”

Personal Data Processing Details

Personal Data are collected for the following purposes and using the following services:

Contacting the User

Contact Form (this Website)

By filling in the contact form with their personal data, the User authorizes this Website to use these details to respond to requests for information, quotes, or any other kind of inquiry as indicated by the form’s header.

Personal Data processed: last name; email address; first name; phone number; company name; various types of data.

Mailing List or Newsletter (this Website)

By registering for the mailing list or newsletter, the User’s email address is automatically added to a contact list that may receive email messages containing information, including commercial and promotional content, related to this Website. The User’s email address may also be added to this list as a result of registering on this Website or after making a purchase.

Personal Data processed: last name; email address; first name; phone number; company name.

Contact Management and Message Sending

These services enable the management of 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 the User views messages, as well as the User’s interactions with them, such as information about clicks on links included in the messages.

Brevo Email (SendinBlue SAS)

Brevo Email is a service provided by SendinBlue SAS for managing email addresses and sending messages.
Personal Data processed: usage data; email address; tracking tools.
Place of processing: France – Privacy Policy.

Personal Data processed: usage data; email address; tracking tools.

Place of processing: France – Privacy Policy.

Mailchimp (Intuit Inc.)

Mailchimp is a service provided by Intuit Inc. for managing email addresses and sending messages.

Personal Data processed: last name; data provided during the use of the service; email address; first name; phone number.

Place of processing: United States – Privacy Policy.

User Database Management

These services allow the Owner to build user profiles by starting from an email address, name, or any other information the User provides to this Website, as well as to track User activities through statistical features. These Personal Data may also be matched with publicly available information about the User (such as social network profiles) and used to build private profiles that the Owner can view and use to improve this Website. Some of these services may also enable the sending of scheduled messages to the User, such as emails based on specific actions performed on this Website.

Brevo Marketing Automation (SendinBlue SAS)

Brevo Marketing Automation is a user database management service provided by SendinBlue SAS.

Personal Data processed: usage data; email address; tracking tools.

Place of processing: France – Privacy Policy.

Leadinfo (Leadinfo B.V.)

Leadinfo is a lead management service provided by Leadinfo B.V. that automatically identifies qualified B2B leads (i.e., companies that have shown interest in becoming paying customers) and enables their management.

Personal Data processed: last name; email address; job position; first name; phone number.

Place of processing: Netherlands – Privacy Policy.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion. This results in the Users’ data flowing through these services, potentially resulting in the retention of this data.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the data processing.
Personal Data processed: usage data; tracking tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Personal Data processed: usage data; tracking tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Traffic Optimization and Distribution

This type of service allows this Website to distribute its content using servers located across different countries and to optimize its performance. The Personal Data processed depends on the characteristics and the way these services are implemented, which by their nature filter communications between this Website and the User’s browser. Given the distributed nature of this system, it is difficult to determine the locations to which the contents, which may contain Personal Data, are transferred.

jsDelivr CDN (jsdelivr.com)

jsDelivr CDN is a traffic optimization and distribution service provided by jsdelivr.com.

Personal Data processed: usage data.

Place of processing: Poland – Privacy Policy.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The integration methods of Cloudflare foresee that it filters all the traffic of this Website, i.e., communications between this Website and the User’s browser, also allowing the collection of analytical data from this Website.

Personal Data processed: tracking tools; various types of data as specified in the service’s privacy policy.

Place of processing: United States – Privacy Policy.

SPAM Protection

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages, and content that are recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the data processing. The use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use. For understanding Google’s use of data, please refer to Google’s partner policies.

For understanding Google’s use of data, please refer to Google’s partner policies.

Personal Data processed: clicks; usage data; keypress events; motion sensor events; touch events; mouse movements; scrolling position; answers to questions; tracking tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Universal Analytics) with IP Anonymization

Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the data processing (“Google”). Google utilizes the Personal 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 Personal Data to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. The anonymization works by shortening Users’ IP addresses within the member states of the European Union or in other countries that are part of the European Economic Area agreement. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the United States.

For understanding Google’s use of data, please refer to Google’s partner policies.

Personal Data processed: usage data; tracking tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Analytics 4

Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the data processing (“Google”). Google utilizes the Personal 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 Personal Data to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. For more information, please refer to Google’s official documentation. For understanding Google’s use of data, please refer to Google’s partner policies.

For understanding Google’s use of data, please refer to Google’s partner policies.

Personal Data processed: usage data; number of Users; session statistics; tracking tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Matomo (self-hosted) (this Website)

Matomo is a statistics software used by this Website to analyze data directly and without the help of third parties.

Personal Data processed: usage data; IP address; tracking tools.

Displaying Content from External Platforms

This 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.

Font Awesome (Fonticons, Inc. )

Font Awesome is a font style display service provided by Fonticons, Inc. that allows this Website to incorporate such content into its pages.

Personal Data processed: usage data; tracking tools.

Personal Data processed: usage data; tracking tools.
Place of processing: United States – Privacy Policy.

Google Fonts

Google Fonts is a font style display service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing. It allows this Website to incorporate such content into its pages.
Personal Data processed: usage data; tracking tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Personal Data processed: usage data; tracking tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Maps Widget

Google Maps is a map display service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing. It allows this Website to incorporate such content into its pages.
Personal Data processed: usage data; tracking tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Personal Data processed: usage data; tracking tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

YouTube Video Widget

YouTube is a video content display service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing. It allows this Website to incorporate such content into its pages.

Personal Data processed: usage data; tracking tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Information on How to Opt Out of Interest-Based Advertising

In addition to any opt-out functionality provided by the services listed in this document, Users may refer to resources such as YourOnlineChoices (EU), Network Advertising Initiative (USA), Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan), or other similar services. These services allow Users to manage tracking preferences for most advertising tools. Therefore, the Data Controller recommends that Users make use of these resources alongside the information provided in this document. Additionally, AppChoices helps Users control interest-based advertising in mobile applications.

Users may also disable certain advertising features through their device settings, such as advertising settings for mobile devices or general ad preferences.

Additional Information for Users

Legal Basis for Processing

The Data Controller may process Personal Data relating to the User if one of the following conditions applies:

The User has given consent for one or more specific purposes.
Processing is necessary for the performance of a contract with the User and/or for pre-contractual measures.
Processing is necessary to comply with a legal obligation to which the Data Controller is subject.
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

In any case, the Data Controller will gladly help 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.

Further Information on Retention Time

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the legitimate interests of the Data Controller shall be retained as long as needed to fulfill those purposes. Users may obtain specific information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain Personal Data until the consent is withdrawn. The Data Controller may also be required to retain Personal Data for a longer period to comply with a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data will be deleted. Therefore, the right to access, erase, rectify, or transfer Personal Data can no longer be exercised once this period has expired.

User Rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Data Controller.

In particular, and to the extent permitted by law, Users have the right to:

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 the 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.
Access their Data. Users have the right to learn if Data is being processed by the Data Controller, 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 request that it 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 Data Controller will not process the 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 Data Controller.
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 hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority or take legal action.

Users are also entitled to receive information regarding the legal basis for data transfers to countries outside the EU or to any international organization governed by public international law (such as the United Nations), as well as the security measures adopted by the Data Controller to safeguard their Data.

Details about the Right to Object

Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing on grounds relating to their particular situation.

Users are reminded that, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. If a User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To find out whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to Exercise Your Rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. Requests are free of charge and will be addressed by the Data Controller as early as possible and always within one month. Any rectifications, deletions, or restrictions of processing will be communicated by the Data Controller to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. Upon request, the Data Controller will inform the User about those recipients.

Additional Information about Data Processing

Legal Defense

The User’s Personal Data may be used by the Data Controller 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 that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information

Upon the User’s request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Website and any third party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Modifications to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information collected automatically through this Web Site (including by third party applications integrated into this Web Site), including: IP addresses or domain names of the computers used by the User who connects with this Web Site, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses this Website which, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Controller)

The natural person, legal entity, public administration and any other body that processes personal data on behalf of the Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.

This Website (or this Application)

The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by this Web Site as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference in this document to the European Union shall be deemed to include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools consisting of small pieces of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.

Legal references

Unless otherwise specified, this Privacy Policy applies only to this Website.