Inkstinct Privacy Policy

UPDATED JULY 4th 2018

Types of Data collected

Among the types of Personal Data that Inkstinct collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, phone number, email address, various types of Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geographic position, username, Camera permission, Precise location permission (non-continuous), Phone permission, Social media accounts permission and Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Inkstinct.
Unless specified otherwise, all Data requested by Inkstinct is mandatory and failure to provide this Data may make it impossible for Inkstinct to provide its services. In cases where Inkstinct specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Inkstinct or by the owners of third-party services used by Inkstinct serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Inkstinct and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Inkstinct (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to 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.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

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

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Data transfer outside the EU, Displaying content from external platforms, Remarketing and behavioral targeting, SPAM protection, Handling payments, Advertising, Infrastructure monitoring, Access to third-party accounts, Content commenting, Content performance and features testing (A/B testing), Device permissions for Personal Data access, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, RSS feed management and Tag Management.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Facebook permissions asked by Inkstinct

Inkstinct may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Inkstinct to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Current City

Provides access to the User’s current location.

Email

Provides access to the User’s primary email address.

Interests

Provides access to the User’s list of interests.

Likes

Provides access to the list of all of the pages the User has liked.

Manage Pages

Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.

Device permissions for Personal Data access

Depending on the User’s specific device, Inkstinct may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of Inkstinct.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Inkstinct.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Precise location permission (non-continuous)

Used for accessing the User’s precise device location. Inkstinct may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Inkstinct to derive the exact position of the User on a continuous basis.

Social media accounts permission

Used for accessing the User’s social media account profiles, such as Facebook and Twitter.

 

Owner and Data Controller

Inkstinct, Inc. – 33 8th Street, suite 523 – San Francisco, California 94103

Owner contact email: privacy@inkstinct.co

Detailed information on the processing of Personal Data

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

This type of service allows Inkstinct to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (Inkstinct)

This service allows Inkstinct to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.

Permissions asked: Current City, Email, Interests, Likes and Manage Pages.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Inkstinct, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Inkstinct. For more information, please check the privacy policies of the relevant services.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

AppTV (AppTV Ltd.)

AppTV is an advertising service provided by AppTV Ltd.

Personal Data collected: Cookies and Usage Data.

Place of processing: Israel – Privacy Policy.

Direct Email Marketing (DEM) (Inkstinct)

Inkstinct uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Inkstinct.

Personal Data collected: email address.

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.

Analytics collected directly (Inkstinct)

Inkstinct uses an internal analytics system that does not involve third parties.

Personal Data collected: Cookies and Usage Data.

Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Inkstinct.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google AdWords conversion tracking (Google Inc.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on Inkstinct.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Inkstinct, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Wordpress Stats (Automattic Inc.)

Wordpress Stats is an analytics service provided by Automattic Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Alexa Metrics (Alexa Internet, Inc.)

Alexa Metrics is an analytics service provided by Alexa Internet, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt Out.

Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Analytics for Firebase (Google Inc.)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

Inkstinct uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

TestFlight (Apple Inc.)

TestFlight is an analytics service provided by Apple Inc.

Personal Data collected: Cookies, email address and Usage Data.

Place of processing: United States – Privacy Policy.

User ID extension for Google Analytics (Google Inc.)

Google Analytics on Inkstinct makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by Inkstinct.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

Personal Data collected: Cookies.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Contact form (Inkstinct)
By filling in the contact form with their Data, the User authorizes Inkstinct to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name, last name and phone number.
Mailing list or newsletter (Inkstinct)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Inkstinct. Your email address might also be added to this list as a result of signing up to Inkstinct or after making a purchase.
Personal Data collected: email address, first name, last name and phone number.

Content commenting services allow Users to make and publish their comments on the contents of Inkstinct.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Comment system managed directly (Inkstinct)

Inkstinct has its own internal content comment system.

Personal Data collected: username.

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Inkstinct.

Google Website Optimizer (Google Inc.)

Google Website Optimizer is an A/B testing service provided by Google Inc.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on consent (Inkstinct)

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Inkstinct.

Personal Data collected: various types of Data.

Data transfer abroad based on standard contractual clauses (Inkstinct)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data collected: various types of Data.

Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (Inkstinct)

If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

Personal Data collected: various types of Data.

Data transfer to countries that guarantee European standards (Inkstinct)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.

Personal Data collected: various types of Data.

Other legal basis for Data transfer abroad (Inkstinct)

If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:

  • the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
  • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
  • the transfer is necessary for important reasons of public interest;
  • the transfer is necessary for establishment, exercise or defence of legal claims;
  • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via Inkstinct.

Personal Data collected: various types of Data.

Inkstinct requests certain permissions from Users that allow it to access the User’s device Data as described below.

Device permissions for Personal Data access (Inkstinct)

Inkstinct requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.

Personal Data collected: Camera permission, Phone permission, Precise location permission (non-continuous) and Social media accounts permission.

This type of service allows you to view content hosted on external platforms directly from the pages of Inkstinct 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.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows Inkstinct to incorporate content of this kind on its pages.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows Inkstinct to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Maps widget (Google Inc.)

Google Maps is a maps visualization service provided by Google Inc. that allows Inkstinct to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Instagram widget (Instagram, Inc.)

Instagram is an image visualization service provided by Instagram, Inc. that allows Inkstinct to incorporate content of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Payment processing services enable Inkstinct to process payments by credit card, bank transfer or other means. To ensure greater security, Inkstinct shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Android Pay (Google Inc.)

Android Pay is a payment service provided by Google Inc., which allows Users to make payments using their mobile phones.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy –Privacy Policy.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service has the purpose of hosting Data and files that enable Inkstinct to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Inkstinct. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service allows Inkstinct to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Inkstinct.

Crashlytics (Google Inc.)

Crashlytics is a monitoring service provided by Google Inc.

Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

This type of service makes it possible to manage 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 when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: email address and first name.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Non-continuous geolocation (Inkstinct)

Inkstinct may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Inkstinct.
The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data collected: geographic position.

This type of service allows Inkstinct and its partners to inform, optimize and serve advertising based on past use of Inkstinct by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Inkstinct with the Facebook advertising network.

Personal Data collected: Cookies and email address.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Inkstinct with the Facebook advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of Inkstinct with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt Out.

Remarketing through Google Analytics for Display Advertising (Google Inc.)

Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

By registering or authenticating, Users allow Inkstinct to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Inkstinct will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Instagram Authentication (Instagram, Inc.)

Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram social network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Facebook Authentication (Facebook, Inc.)

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

This type of service analyzes the traffic of Inkstinct, 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 Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

This type of service allows Inkstinct to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.

Feedburner (Google Inc.)

Feedburner is a service to manage RSS feeds provided by Google Inc. It allows the collection of statistics on what content is consumed and to insert ads in it.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

This type of service helps the Owner to manage the tags or scripts needed on Inkstinct 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 LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Inkstinct may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Inkstinct adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Inkstinct, Users can check the relevant sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Inkstinct may send push notifications to the User.

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Inkstinct depends on the payment system used.

Inkstinct may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

The rights of Users

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

In particular, Users have the right to do the following:

  • 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 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. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, 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 ask for it to 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 Owner will not process their 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 Owner.
  • 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 any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Inkstinct or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, Inkstinct may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Inkstinct and any third-party services may collect files that record interaction with Inkstinct (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Inkstinct does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Inkstinct and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Inkstinct (or third-party services employed in Inkstinct), which can include: the IP addresses or domain names of the computers utilized by the Users who use Inkstinct, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using Inkstinct who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Inkstinct. The Data Controller, unless otherwise specified, is the Owner of Inkstinct.

Inkstinct (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Inkstinct as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User’s device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Inkstinct, if not stated otherwise within this document.

Request your data

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