Privacy

Privacy Policy of www.gongcapital.com

This Application collects some Personal Data from its Users.

 

This document contains a section dedicated to Users in the United States and their privacy rights.

This document contains a section dedicated to Users in Switzerland and their privacy rights .

This document contains a section dedicated to Users residing in Brazil and their privacy rights .

 

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Data Controller

Gong Capital Spa
Foro Bonaparte 70 – 20121 Milan
VAT number and tax code 09981420962

Owner’s email address: info@gongcapital.com

Types of Data collected

Among the Personal Data collected by this Application, independently or through third parties, there are: Usage data; Tracking Tools.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of the Data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation. Users who have doubts about which Data are mandatory are encouraged to contact the Owner. Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application has the purpose of providing the Service requested by the User, in addition to further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application.

Method and place of processing of the collected data

Treatment methods

The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Place

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

Retention period

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the consent of the Users.

Purpose of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Viewing content from external platforms.

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.

Details on the processing of Personal Data

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

 

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. Such services are often called widgets , which are small elements placed on a website or application. They provide specific information or perform a particular function and often allow interaction with the user. This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts

Google Fonts is a character style visualization service managed by Google LLC or by Google Ireland Limited, depending on how the Owner manages the processing of Data, which allows this Application to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tools.

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

Category of Personal Information collected under the CCPA: information about activities on the Internet or other networks.

This type of treatment constitutes:

  • a Sale in the United States

Font Awesome ( Fonticons , Inc. )

Font Awesome is a font style visualization service operated by Fonticons , Inc. which allows this Application to integrate such contents within its pages.

Personal Data processed: Usage data; Tracking Tools.

Place of processing: United States – Privacy Policy .

Category of Personal Information collected under the CCPA: information about activities on the Internet or other networks.

 

Cookie Policy

This Application uses Tracking Tools. To find out more, Users can consult the Cookie Policy .

Further information for users

Legal basis of the processing

The Owner processes Personal Data relating to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes.
  • the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Learn more about storage time

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the consent of the Users.

Therefore:

  • Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
  • Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User’s consent, the Owner may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

User rights under the General Data Protection Regulation (GDPR)

Users can exercise certain rights with reference to the Data processed by the Owner.

In particular, within the limits established by law, the User has the right to:

  • revoke your consent at any time. The User may revoke the previously expressed consent to the processing of their Personal Data.
  • object to the processing of their Data. The User can object to the processing of their Data when it takes place by virtue of a legal basis other than consent.
  • access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
  • obtain the limitation of treatment. The User may request the limitation of the processing of their Data. In this case the Owner will not process the Data for any purpose other than their conservation.
  • obtain the cancellation or removal of your Personal Data. The User may request the deletion of their Data by the Owner.
  • receive your Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without obstacles to another owner.
  • lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad including to any international organization regulated by international law or constituted by two or more countries, such as the UN, as well as regarding the measures of security adopted by the Owner to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge and without providing any reason. If Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for these purposes. To find out whether the Owner processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise their rights, Users can direct a request to the Owner’s contact details indicated in this document. The request is free and the Owner will respond as quickly as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, cancellations or limitations of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Owner communicates these recipients to the User if he requests it.

Additional information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of the processing, the categories of recipients of the personal data, if any, the retention period and other information on the Personal Data can be found in the section entitled “Detailed information on the processing of Personal Data” within this document .

Your rights under the Federal Data Protection Act

Users can exercise some rights relating to their data within the limits of the law, including the following:

  • right of access to Personal Data;
  • the right to object to the processing of their Personal Data (which also allows Users to request the limitation of the processing of Personal Data, the deletion or destruction of Personal Data, the prohibition on disclosure of Personal Data to third parties);
  • right to receive your Personal Data and to transfer it to another data controller (data portability);
  • right to request rectification of incorrect Personal Data.

 

How to exercise these rights

Any requests to exercise the User’s rights can be addressed to the Owner through the contact details provided in this document. These requests are free and the Owner will respond as quickly as possible, providing Users with the information required by law.

Additional information for Users in Brazil

This section of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this Application and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we “, “our” or “ours”).
This section applies to all Users in Brazil (such Users are referred to herein simply as “you”, “your”, “you” or “yours”), pursuant to the “Lei Geral de Proteção de Dados and, for such Users, prevails over any other possibly divergent or conflicting information contained in this privacy policy.
This part of the document uses the term “personal information” as defined by the LGPD .

Legal bases on which we process your personal information

We process your personal information only if one of the legal bases for such processing exists . The legal bases are as follows:

  • your consent to the processing activities in question;
  • compliance with legal obligations that we are required to satisfy;
  • the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
  • studies conducted by research institutions, preferably carried out on anonymized personal information;
  • the execution of a contract and related pre-contractual obligations, if you are a party to such contract;
  • the enforcement of our rights in court, administrative proceedings or arbitration;
  • the defense or physical safety of you or a third party;
  • health protection – in the context of procedures implemented by entities or professionals in the healthcare sector;
  • our legitimate interests, provided that your fundamental rights and freedoms do not override such interests; And
  • credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out which categories of personal information are processed, you can refer to the “Details on the processing of Personal Data” section in this document.

Why we process your personal information

To find out why we process your personal information, please refer to the “Details on the processing of Personal Data” and “Purpose of the Processing of Collected Data” sections in this document.

Your privacy rights in Brazil, how to make a request and how we will handle it

Your privacy rights in Brazil

You have the right to:

  • obtain confirmation of the existence of processing activities regarding your personal information;
  • access your personal information;
  • obtain rectification of your incomplete, inaccurate or out-of-date personal information;
  • obtain the anonymisation , blocking or deletion of unnecessary or excessive personal information, or that information which is processed in conflict with the provisions of the LGPD;
  • obtain information regarding the possibility of giving or refusing your consent and the related consequences;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your explicit request, the portability of your personal information (with the exception of anonymized information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
  • obtain the deletion of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 LGPD apply;
  • withdraw your consent at any time;
  • lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
  • oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And
  • request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you in any way suffer any treatment that is unfavorable to you, following the exercise of your rights.

How to submit a request

You can send an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and in what time we will handle your request

We will do our best to respond to your request as soon as possible.
In any case, if it is impossible for us to do so, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately satisfying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate to you the natural or legal person to whom your requests should be addressed.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please be sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you instead require complete information. In the latter case, we will respond within 15 days of your request, providing you with all the information regarding the origin of your personal information, the confirmation or not of the existence of personal information concerning you, all the criteria used for the processing and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you decide to make a request for rectification, deletion, anonymization or blocking of personal information , we will ensure that we immediately inform the other parties with whom we have shared your personal information of your request so that they can also satisfy your request – except in cases where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside of Brazil where permitted by law

We may transfer your personal information outside of Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedural bodies, as provided for by the tools made available by international law;
  • when the transfer is necessary to defend the life or physical safety of you or a third party;
  • when the transfer is authorized by the ANPD;
  • when the transfer arises from an obligation assumed in the context of an international cooperation agreement;
  • when the transfer is necessary for the exercise of public order or for the performance of a public service;
  • when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and related pre-contractual obligations, or the normal exercise of rights in judicial , administrative or arbitration proceedings.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

 

Internet or other electronic network activity information

Personal Information collected or disclosed : Usage data, Tracking tools

Purposes :

  • Viewing content from external platforms

Retention period: for the time necessary to fulfill the purpose

Sold or Shared : Yes

Targeted Advertising: : No

Third-parties: Google LLC, Fonticons , Inc.

 

You can read the definitions of these concepts inside the “ Definitions and legal references section ” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities you can refer to the “ Your privacy rights under US state laws ” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “ Detailed information on the processing of Personal Data ” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
  • the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
  • the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
  • the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
  • the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
  • the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have

  • The right to opt out of the processing of your Personal Information for Targeted Advertising ;
  • The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control , such as for example the Global Privacy Control (“ GPC ”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Learn more about the treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares to be aware that the Owner may be obliged to reveal the Data by order of public authorities.

Specific information

Upon request of the User, in addition to the information contained in this privacy policy, this Application 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 needs related to operation and maintenance, this Application 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.

Changes 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 Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details contact he has. Please therefore 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 Owner will collect the User’s consent again, if necessary.

 

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Sensitive Personal Information

Sensitive Personal Information means all Personal Information that is not publicly available and that reveals information considered sensitive under applicable privacy legislation.

Usage Data

This is information collected automatically through this Application (also by third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier ), 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 operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and details relating to the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses this Application who, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Manager)

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

Data Controller (or Data Controller)

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 and the tools adopted, including security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Application as defined in the relative terms (if available) on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, in exchange for money or other consideration , as defined by applicable US state privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements established by applicable law does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating verbally, in writing or by electronic or other means, of a consumer’s Personal Information to a third party. for cross- context behavioral advertising , whether in exchange for money or for other consideration, including transactions between a company and a third party relating to cross- context behavioral advertising for the benefit of a company where no money is exchanged, such as defined by California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements of California privacy laws does not constitute a sharing of your Personal Information.

Targeted advertising

Targeted Advertising means the display of advertisements to a consumer for whom the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and on unaffiliated websites or online applications to predict the preferences or interests of such consumer, as defined by applicable U.S. state privacy law.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons , integrated scripts, e- tags and fingerprinting – which allow Users to be tracked, for example by collecting or saving information on the User’s device.

Legal references

This privacy policy is drawn up on the basis of multiple legislative systems.

Unless otherwise specified, this privacy policy applies exclusively to this Application.