Privacy Policy

Welcome to Marcella di Martino and my website at www.marcelladimartino.com. This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we (that is me, Marcella di Martino of Via Germanico 184, Rome, 00192, Italy, and the third parties involved in the operation of my website)  collect from you when you visit our website and use our services. If you have any questions about this policy or about data protection at Marcella di Martino in general, please contact me.

 

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data.

WHY DO I HAVE A PRIVACY POLICY?

Italy’s Data Protection Code (DPC), and the EU’s General Data Protection Regulation (GDPR), control how your Personal Data is used by me. I am also required to explain which Personal Data I collect from you via my website, what I use it for, when I delete it, and how your data is protected.

 

MY LEGAL BASIS FOR USING YOUR PERSONAL DATA

I only use your Personal Data when I have a legal basis for doing so. The legal basis for using your data will depend on what I need to do but includes:

 

  • Contract: to provide my online services
  • Legal obligation: to comply with the law
  • Legitimate Interest: where necessary for my interests or the interest of a third party, after carefully considering any effect to individual rights and freedoms
  • Consent: where clear consent is given to use your data for a specific purpose.

 

For more information on my legal basis for sharing, please contact me.

WHAT PERSONAL DATA I COLLECT

The types of information I collect about you depend on your use of my services and the ways that you interact with me.

Personal Data you provide directly to me when you:

  • access my websites;
  • subscribe to my services, marketing, or download my publications;
  • request marketing to be sent to you;
  • give me feedback, submit a warranty claim, or fill out my repair registration form, or contact me.

Personal Data I collect from you via third-party sources includes the following:

  • Analytics providers, advertising networks, and communication services providers, including email providers and social networks, when you allow access to your information available on third-party services or networks. This may include data collected through cookies, pixels, and similar tracking technologies, which help me understand your interactions with my advertisements and improve my marketing efforts;
  • Auditors, regulators, and supervisory bodies; and
  • Public authorities and law enforcement agencies.

The data I collect from the sources mentioned above includes:

  • Contact data, identity data: first name, last name, title, job title, date of birth, gender, address, email address, telephone number, or similar identifier.
  • Transaction data: details of services you have requested or purchased from me.
  • Cookies and tracking information: such as internet protocol (IP) address, your login data, access times, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, the Uniform Resource Locator (URL), and other technology on the devices you use to access this website.
  • Usage data: information about how you use, interact with, and access my website, and information relating to my business. This includes system information related to your device, system, or network (IP address, hardware model, operating system version, hardware settings, system and application configuration data, and MAC address) and how your device, system, or network interacts with my website (such as statistical information, network connection indicators, system crashes, data logs, and routing).
  • Marketing and communications data: your preferences in receiving marketing from me and my third parties, and your communication preferences.
  • Aggregated data: statistical or demographic data. For example, I may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyze general trends in how users are interacting with my website to help improve the website and my service offering.

CHANGE OF PURPOSE

I will only use your Personal Data for the purposes for which I collected it as detailed above, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If I need to use your Personal Data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

 

THIRD-PARTY SERVICES AND CONTENT

I use content or service offers of third-party providers on the basis of my legitimate interest to integrate their content and services. This always requires that the third-party providers of this content are aware of your IP address and system information related to your device, system, or network. The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any.

 

 

COOKIES

I use so-called cookies on my website. Cookies are pieces of information that are transmitted from my web server or third-party web servers to your web browser and stored there for later retrieval. As set out in the DPC and the EU’s Privacy and Electronic Communications Directive (PECD), I need to obtain consent for the use of non-essential cookies. The legal basis for the use of essential cookies is my legitimate interest, and the legal basis for the use of non-essential cookies is your consent. For further information on the cookies I use, please refer to my Cookie Policy.

My website also uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter my website, the following Personal Data is transferred to me: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; e) Time of your visit to my website. The legal basis for processing is both your consent and my legal obligation.

DATA SHARING AND TRANSFER

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal

If necessary, I transfer your Personal Data within Alain Aster. Access to your Personal Data is only granted to authorized employees who have a genuine need to access your data.

External

Personal Data is transferred to my service providers in the following instances: a) in the context of fulfilling my contract with you; b) to use marketing services and to advertise my business; c) to communicate with you; d) to provide my website, and e) to state authorities and institutions as far as this is required or necessary.

 

International transfers

I may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, I have contractual arrangements including non-disclosure agreements, data processing agreements, and standard contractual clauses regarding such transfers. I take all reasonable technical and organizational measures to protect the Personal Data I transfer.

 

SECURITY OF YOUR PERSONAL DATA

I take the security of your personal data very seriously. I have implemented various strategies, controls, policies, and measures to keep your data secure and keep these measures under close review. I protect your data by using encryption techniques, and I use other safeguards such as firewalls and password protection. This means that your data is protected and only accessible on a need-to-know basis. I also ensure that there are strict physical controls which restrict access to your personal data to keep it safe.

 

RETENTION OF YOUR PERSONAL DATA

In broad terms, I will only retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that I have the data in the first place.

 

To determine the appropriate retention period for personal data, I consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements. Personal Data will be deleted/destroyed or anonymized at the end of the retention period.

 

LINKED SITES

For your convenience, there may be hyperlinks on my website that link to other websites. I am not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that I do not own or control.

SOCIAL MEDIA

I am present on social media on the basis of my legitimate interest. If you contact or connect with me via social media, I and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting me is to handle your request, and the bases are both your consent and my legitimate interest.

YOUR RIGHTS AND PRIVILEGES

Privacy rights

You can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing; and
  • The right to data portability.

Updating your information and withdrawing your consent

If you believe that the information I hold about you is inaccurate or request its rectification or deletion or object to legitimate interest processing, please do so by contacting me.

Access Request

In the event you want to make a Data Subject Access Request, please contact me. I will respond to requests regarding access and correction as soon as reasonably possible. Should I not be able to respond to your request within thirty (30) days, I will tell you why and when I will be able to respond to your request. If I am unable to provide you with any Personal Data or to make a correction requested by you, I will tell you why.

Complaint to a supervisory authority

You have the right to lodge a complaint about our processing of personal data with a supervisory authority responsible for data protection. The competent supervisory authority in relation to our services is Garante per la Protezione dei Dati Personali (the “Garante”) Piazza Venezia n. 11 – 00187 Rome (Italy), www.garanteprivacy.it. However, we would appreciate the opportunity to address your concerns before you contact the Garante.

What I do not do

  • I do not request Personal Data from minors and children;
  • I do not process special category data without obtaining prior specific consent;
  • I do not use automated decision-making including profiling; and
  • I do not sell your Personal Data.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you, please contact me.

CHANGES

The first version of this policy was issued on Thursday, 15th May, 2025, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date. 

 

 

 

 

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