Privacy Policy

INTRODUCTION This Privacy Policy is intended to describe the way in which thegentlelady.com website manages and processes the personal data of users who visit this website. This is an information that has been drawn up pursuant to:

Legislative Decree n. 196/2003 (Code regarding the protection of personal data), updated and amended by Legislative Decree no. 101/2018;
European Regulation n. 679/2016 (GDPR – General Data Protection Regulation).

The information is prepared to inform users who interact with the web services provided by thegentlelady.com site. The information is also inspired by Recommendation no. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. 29 of the directive n. 95/46 / EC, adopted on 17 May 2001 to identify some minimum requirements for the collection of personal data online, and, in particular, the methods, timing and nature of the information that the data controllers must provide to users when they connect to web pages, regardless of the purpose of the link. DEFINITIONS Personal Data Personal data is information that allows you to directly or indirectly identify a natural person (such as: name, surname, email, telephone number). User For the purposes of this information, a “user” is defined as the natural person who browses and uses this Site. While browsing this Site, a notice will appear to the user asking him to authorize the tracking of his “cookies”. By authorizing the tracking of “cookies”, the user’s usage data will be anonymized (“anonymized cookies”) not allowing this Website to directly identify the user. Interested If the user who visits this site authorizes the processing of his personal data (by filling out a contact form), he will be defined as “interested”, or the person to whom the personal data refer. Usage Data This is the information that this site collects automatically without directly identifying users. In particular, the following constitute usage data of this site:

the IP addresses or domain names of the computers used by the user who connects to this Site;
the addresses in URI (Uniform Resource Identifier) ​​notation;
the time of the user’s request;
the method used in submitting the request to the server;
the user’s country of origin;
the characteristics of the browser and operating system used by the user;
the time duration of the user’s visit to the pages of this site;
the user’s visit path within the Site, with particular reference to the sequence of pages consulted, the parameters relating to the user’s operating system and IT environment.

Data Controller The natural or legal person who decides how the personal data of the data subjects will be used. The data controller establishes the methods of use of users’ personal data and guarantees their protection together with the Personal Data Protection Officer (DPO). Responsible for the protection of personal data (DPO) The natural or legal person who ensures that the personal data of users is protected, through the adoption of technical preventive measures and also through the adoption of internal codes of conduct. Data Processor (or Manager) The natural or legal person who is authorized by the Data Controller to process Personal Data, to process the personal data of the interested parties. This Site All web pages of the site https://thegentlelady.com/ that contain information and information content. Cookie Code fragment that collects data within the device used by the user for navigation. DATA CONTROLLER AND DATA PROTECTION MANAGER The data controller of this site is thegentlelady.com. Your contact details are:

mail: info@thegentlelady.com.

The data processors of this site are (being updated). The data protection officer (DPO) is Mattia Mancin. His contact details are:

mail: mattia.mancin.01@gmail.com;

REGULATORY SOURCES COMPLIANCE WITH EU REGULATION N. 679/2016 – GDPR (GENERAL DATA PROTECTION REGULATION) This Privacy Policy complies with the European regulation EU no. 679/2016 better known as “GDPR” (General Data Protection Regulation). This website and the data controller respect the consideration n. 82 and n. 83 of the EU regulation no. 679/2016 better known as “GDPR” (General Data Protection Regulation). REGISTER OF PROCESSING ACTIVITIES This website and the data controller, in accordance with the provisions of art. 30, paragraph n. 1, of the European regulation UE n. 679/2016, have created the “Register of processing activities”. The “Register of processing activities” possesses the requirements indicated in art. 30, paragraph n. 1 (letters: a, b, c, d, e, f, g) of the European regulation UE n. 679/2016. Pursuant to art. 30, paragraph n. 3 of the European regulation UE n. 679/2016, the “Register of processing activities” is kept in electronic format. The “Register of processing activities” in electronic format is kept in management software covered by cryptography which is not accessible by users and third parties. In the event of a request for access by the competent authorities, this website and the data controller, in accordance with the provisions of art. 30, paragraph n. 4 of the European regulation UE n. 679/2016, will make the register available to the supervisory authority. This website and the data controller have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk in accordance with the provisions of art. 32, paragraph n. 1 (letters: a, b, c, d, e, f, g) of the European regulation UE n. 679/2016.

WE INVITE YOU TO READ OUR PRIVACY POLICY, BELOW ILLUSTRATED INFORMATION ON PRIVACY Scope of data communication The personal data provided may be disclosed to third parties to comply with legal obligations, in execution of orders from public authorities to this effect. legitimized or still to assert or defend a right in court. Type of data processed and purpose of processing Navigation data: The computer systems and software procedures used to operate this site acquire, in normal operation, some personal data which are then implicitly transmitted in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. Data provided voluntarily by users / visitors: If users / visitors, connecting to this site, send their personal data to access certain services, or to make requests via e-mail, this involves the acquisition by the data controller of the address of the sender and / or any other personal data that will be processed exclusively to respond to the request, or for the provision of the service. The personal data provided by users / visitors will be disclosed to third parties only if the communication is necessary to comply with the requests of the users / visitors themselves. Methods of processing and data retention period Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. For users subscribed to the newsletter: as soon as the user unsubscribes from the newsletter, personal data is completely deleted from our management system. For our clients: As soon as the consultancy relationship with the client is terminated, the personal data is stored for a period of 1 month. After the 1 month period, the personal data of former customers or former employees are permanently deleted. Security measures for data retention This site thegentlelady.com observes specific security measures to prevent data loss, illicit or incorrect use and unauthorized access. To ensure data retention in conditions of maximum security, this site uses software with encrypted technology, with double access authentication. This system prevents access to unauthorized persons for processing and prevents the reading of the collected data. Optional supply of data Apart from that specified for navigation data, users / visitors are free to provide their personal data. Failure to provide them may only result in the impossibility of obtaining what is requested. Place of data processing The processing connected to the web services of the site indicated above takes place both at the headquarters of the company of thegentlelady.com site, and at the company headquarters and / or at the headquarters of the hosting and / or management company. website and are handled only by technical staff of the office in charge of processing, or by persons in charge of occasional maintenance operations. No data deriving from the web service is communicated or disseminated. The personal data provided by users who submit requests to send information material are used only to perform the service or provision requested and are disclosed to third parties only if this is necessary for this purpose. Rights of the interested parties The subjects to whom the personal data refer (also defined with the term “interested parties”) have the right at any time to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, to verify accuracy or request its integration or updating, or correction.

Pursuant to the GDPR, the interested party has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their processing. The subjects to whom the personal data refer have the right to:

Revoke the consent to the processing;
Obtain confirmation or not of the existence of personal data;
Know to whom your data is transmitted;
Obtain the correction, cancellation, integration of their data;
Propose a complaint to the Privacy Guarantor;
Know if the data is subject to profiling;
Transfer your data to another provider (right of portability).

If you want to ask for more information on the processing of your data or if you want to exercise one of the rights mentioned above, you can send an email to the following address: info@thegentlelady.com. On what legal basis do we process your data When we process your personal data for the purposes indicated in this Notice we rely on one or more of the following legal grounds:

Consent: we ask for your consent to use your data, to update you on our content, to send you information about our services and for profiling (i.e. to analyze the interests and behaviors of visitors to our site and to improve our marketing campaigns) .
Contractual scope: when you enter into a contract of any kind with us, your personal data will be processed to pursue the purposes of the service you have purchased.
Legal obligations: when strictly necessary, we will process your personal data to comply with a legal obligation, an order imposed by the supervisory authority, a binding tax assessment.

INFORMATION ON COOKIES What are cookies? Cookies are information that a server can send to your PC, smartphone or tablet when you visit a website or use a social network. The same server that transmitted them, then, can read and record the cookies located on your PC, smartphone or tablet to obtain various types of information. Cookies have different functions: in many cases they are useful because they make navigation easier and faster, as happens with technical cookies, used for example to save language preferences or a shopping cart. In other cases, however, cookies are used to monitor users while browsing; so-called profiling cookies record information on what you buy or may want to buy, analyzing your readings, your hobbies, your travels, to customize the advertising that is shown to you when you open the email or browse a social network. Then there are third-party cookies, that is information that is recorded by sites other than those you have visited and that are used for profiling purposes. Further information can be found on the website of the Privacy Guarantor. We remind you that, by proceeding with the navigation on this site or by clicking on the ok and X buttons on the banner of the brief information, you declare that you have read and accepted the privacy policy and the cookies policy, thus consenting to the use of cookies on this site.

Types of cookies we use Two types of cookies can be used on the site: ‘session cookies’ and ‘persistent cookies’:

Session cookies are temporary cookies that remain on your device until you leave the site.
The ‘persistent cookie’ remains on your device for longer or until you delete it manually.

The cookies used by our site Technical cookies Technical cookies are those whose use does not require the user’s consent. These cookies are essential to allow you to browse a website and use all its features. Without these cookies, which are absolutely necessary, a website could not provide some services or functions and navigation would not be as smooth and easy as it should be. A cookie of this type is also used to store a user’s decision on the use of cookies on the website. Other technical cookies are those that allow, for example, the saving of preferences relating to the language or the shopping cart. WordPress cookies This site was developed on the wordpress platform, therefore it uses cookies implemented by the aforementioned platform. The stored cookies concern those who have registered an account on the wordpress blog and those who comment on articles. The cookies used by wordpress are:

wordpress_ [hash]
wordpress_logged_in_ [hash]
wp-settings- {time} – [UID]
cookie_notice_accepted (it is the cookie used to store a user’s decision on the use of cookies on the website)

All these cookies are persistent and are released to ensure a better browsing experience on this site. Profiling cookies This site uses cookies of this type. Advertising cookies are installed to show site visitors content related to their preferences. They can therefore be used to show advertising content targeted to the interests of the person. Cookies of this type work in collaboration with third-party sites and can keep track of past browsing on pages on different domains. Cookies of this type usually keep track of the user’s IP address as well as other information, some of which may be personal. Third-party cookies These cookies are used in order to collect information on the use of the site made by users anonymously such as: pages visited, time spent, origins of the traffic of origin, geographical origin, age, gender and interests to statistical purposes and marketing campaigns. These cookies are sent from third-party domains external to the site. Google analytics cookies with anonymized IP Our pages use third-party performance cookies from Google Analytics with anonymized IP (service offered by Google, Inc.) to allow us to collect anonymously and examine the behavior of visitors while using the site and to improve its usability and user experience. They are defined anonymous as they cannot be used to identify specific individuals.

Through the use of the Google Analytics panel, it is possible for us to understand whether the visits were made by new or returning visitors by verifying how the pages are navigated (entry and exit links, movements between pages, residence times, geographical origin, etc.). For further information relating to Google Analytics, you can consult the websites: https://www.google.it/policies/privacy/partners/ https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage It is possible to disable the action of Google Analytics through the tools provided by Google. For information on this, consult the website: https://tools.google.com/dlpage/gaoptout The cookies used by Google Analytics are:

_ga (persistent – 2 years)
_utma (persistent – 2 years)
__utmb (session)
__utmt (session)
__utmz (session)
_gat (persistent – 10 minutes)

How to check or delete cookies Most browsers are configured to accept, check or possibly disable cookies through the settings. For more information on managing cookies, visit the appropriate links:

Internet explorer

Chrome / windows phone

Safari / IOS

Firefox

For more information on cookies and to manage cookie preferences (first and / or third party) you can also visit the www.youronlinechoices.com platform. Social network buttons and widgets To ensure that the contents of a site can be shared on social networks by site visitors, it is possible to integrate the tools (widgets) made available to the social networks themselves into the pages. These tools (usually blocks of code inserted in the pages of the host site) can collect third-party cookies installed by social networks (for example Facebook, Twitter, YouTube, etc.); the site does not share any information with these widgets. For more information about the cookies of the main social networks, you can visit the sites:

Facebook privacy

Instagram privacy

Youtube Privacy

Twitter privacy

LinkedIn Privacy

Pinterest Privacy

Whatsapp Privacy

Privacy Telegram

Consent to the use of cookies

We remind you that if you do not consent to the use of cookies and decide to disable the cookies we use, this could affect your user experience while visiting our site (preventing you from seeing some parts or some web pages).

SECURITY PROTOCOLS This website uses the secure communication protocol “https” (Hypertext Transfer Protocol Secure). The “https” protocol is used to ensure secure communication between two IT devices connected to the internet. In this way, if you fill out one of the contact forms within our site, your message will be transmitted within an encrypted connection, using asymmetric encryption (thanks to the TLS – Transport Layer Security and SSL – Secure Sockets Layer protocols). The “https” protocol guarantees: – authentication of the website visited; – the protection of privacy (confidentiality or confidentiality); – the integrity of the data exchanged between the communicating parties. We use the “https” protocol to protect your data through a two-way encryption of communications between a client and a server. This allows us to protect your data from possible operations of: – eavesdropping à action by which the private conversation between the parties is secretly intercepted without their consent; – opertampering literally “tampering with or altering the communication”, an action by which the contents of a web communication are falsified. In practice, the “https” protocol guarantees that: – the user is communicating exactly with the desired website (as opposed to a fake site); – the contents of communications between the user and the website cannot be intercepted or altered by third parties. PROFILING AND MARKETING ACTIVITIES The website company thegentlelady.com, through this website, carries out marketing and profiling activities. Marketing and profiling activities are carried out only towards people who have given their consent to the processing of personal data. The marketing activities are aimed at making the services and contents created by thegentlelady.com company known to interested persons who have given their consent to the processing of data. Profiling activities are carried out to measure the results of marketing campaigns; these activities consist in the collection and processing of data of users interested in a service to divide them into groups based on their behavior. To carry out marketing and profiling activities, thegentlelady.com company uses the following tools. Facebook Pixel This website uses a script called “Facebook Pixel”. We use this tool to collect statistical data that allow us to measure the effectiveness of paid advertising. Thanks to the Facebook Pixel we can understand the actions that people perform on our website. The data we collect is used to:

Make sure your ads are shown to the right people;
Create audience groups to target ads;
Take advantage of the additional advertising tools of the platform on which we advertise.

We use the Facebook Pixel to carry out “remarketing” and “retargeting” activities; thanks to these activities we use the cookies you leave on our site, without identifying you. In this way your browsing data is not linked to your identity and your personal data. The data collected thanks to the Facebook Pixel are used only by us and by external professionals who support us in marketing and online advertising activities. Linkedin Insight Tag This website uses a script called “Linkedin Insight Tag”. The LinkedIn Insight Tag is a code snippet, in lightweight “JavaScript” language, that adds a cookie to users’ browsers every time they visit the site. Thanks to this tool we can record when a Linkedin member performs a certain action on our website (such as booking a service or leaving the email). We use this tool to collect statistical data that allow us to measure the effectiveness of paid advertising. Thanks to the Linkedin Insight Tag we can understand the actions that people perform on our website. The data we collect is used to:

Make sure your ads are shown to the right people;
Create audience groups to target ads;
Take advantage of the additional advertising tools of the platform on which we advertise.

We use the Linkedin Insight Tag to carry out “remarketing” and “retargeting” activities; thanks to these activities we use the cookies you leave on our site, without identifying you. In this way your browsing data is not linked to your identity and your personal data. The data collected thanks to the Linkedin Insight Tag are used only by us and by external professionals who support us in marketing and online advertising activities. TikTok Pixel This website uses a script called “TikTok Pixel”. We use this tool to collect statistical data that allow us to measure the effectiveness of paid advertising on the social network called “TikTok”. Thanks to the TikTok Pixel we can understand the actions that people, who have a TikTok account, perform on our website. The data we collect is used to:

Make sure your ads are shown to the right people;
Create audience groups to target ads;
Take advantage of the additional advertising tools of the platform on which we advertise.

We use the TikTok Pixel to carry out “remarketing” and “retargeting” activities; thanks to these activities we use the cookies you leave on our site, without identifying you. In this way your browsing data is not linked to your identity and your personal data. The data collected thanks to the TitkTok Pixel are used only by us and by external professionals who support us in marketing and online advertising activities. If you have a TikTok account we do not collect any personal data that you have entered on TikTok. After carrying out an advertising campaign on TikTok, we analyze some statistical data, processed by the TikTok platform dedicated to advertisers. In this way we study the way in which TikTok users interact with our advertising content, without directly identifying the recipients of the ads and without processing their personal data entered within the platform. Newsletter and email marketing software If you decide to subscribe to our newsletter, we will ask you to enter your personal data (name, surname, email) in a contact form. We will use your personal data to send you emails that will update you on our content (blog articles, videos, etc ..). If you decide to receive “updates on our services”, we will use your data to send you emails in which we will explain if our services can be useful to you. When you enter your details in the contact form, the data will end up in an “email marketing” software called Mailchimp. Access to the Mailchimp software is covered by “end to end” encryption; to access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account. The data collected on Mailchimp are consulted only by us and by external professionals who support us in email marketing activities. You can choose at any time to unsubscribe from our newsletter; to unsubscribe you can click on a specific button that you will find in our emails. After clicking on the delete button, your data will be deleted immediately by the “email marketing” software. Messenger BOT To manage our newsletter, the publication of our content and the communication of our commercial offers, we use a chatbot within the Facebook messaging application called “Messenger”. You can decide to receive our communications, either by email to your email address, or by subscribing to our Messenger BOT. Our Messenger BOT collects your personal data entered on Facebook (name, surname, email) and uses them to send you messages in the Facebook messaging application called “Messenger”. We will use your personal data to send you chat messages that will contain updates on our content (blog articles; podcast episodes; videos; communications about our services). When you agree to subscribe to our Messenger BOT your personal data entered on Facebook (name, surname, email) will end up in an external software called ManyChat. Access to the ManyChat software is covered by “end to end” encryption. To access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account. The data collected on ManyChat is consulted only by us and by external professionals who support us in Messenger marketing activities. You can choose at any time to unsubscribe from our Messenger Bot;

to unsubscribe you can click on a specific button that you will find inside our chat messages. After clicking on the delete button your data will be deleted immediately by the “ManyChat” software. SERVICES In this section we will explain how we use your data if you request one of our services. Thegentlelady.com services When you request one of thegentlelady.com services or products we use the data you entered in the contact form to respond to your requests and to provide you with the service you have chosen. To protect your data, we adopt predefined processing procedures and follow an internal code of conduct; in this way we protect your data securely. In data processing we could use: – “cloud” storage tools, applications or services; – e-mail tools, applications or services; – data transfer tools, applications or services such as Wetransfer. These activities may involve the transfer of data to servers located outside the European Union, regardless of our will. To carry out our services we use these software: Gmail, Google Drive, Google Calendar, Evernote, Dropbox, Slack, Zapier. We invite you to consult the privacy policy of these programs by clicking on these pages:

Gmail

Google Drive

Google Calendar

Google Privacy Policy

Mailchimp

Dropbox

Slack

Zapier

Typeform

Basecamp

Invoices in the cloud

If you request one of thegentlelady.com services or products, your personal data will be disclosed to third parties only when it is necessary for the processing of your file. The subjects to whom we will be able to communicate your personal data are:

Internal staff and collaborators of thegentlelady.com who will be responsible for the processing of your project;
External Web Agencies that collaborate with us for the realization of your project;
External professionals who will be in charge of the processing of your project;
External accounting professionals who collaborate with us for the accounting management of our company;
Public administrations (if it will be necessary to contact them for the processing of your project).

Online training services and video courses When you buy one of thegentlelady.com video courses, the data you entered to complete the payment will end up in a software called “Kajabi”. Access to the Kajabi software is covered by “end to end” encryption. To access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account. The data collected on Kajabi are consulted only by us and by external professionals who support us in marketing activities. You can choose at any time to delete your data on Kajabi by canceling your subscription to our courses.