Privacy and Cookies Policy

Privacy & Cookie Policy

This Application collects some Personal Data from its Users.


Data Controller and Owner

Bowhurst London Ltd, India House, 45 Curlew Street, London, SE1 2ND, UK
legal@bowhurst.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

Cookie, Usage Data, Email, First Name, Last Name, Phone number, Country, State, Province, ZIP/Postal code and Geographic position.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

The User assumes responsibility for the Personal Data of third parties published or shared through this Application and declares to have the right to communicate or broadcast them, thus relieving the Data Controller of all responsibility.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take 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 Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (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 Data Controller at any time.

Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Application to provide its services, as well as for the following purposes:

Handling payments, Hosting, Analytics, Displaying content from external platforms, Content performance and features testing (A/B testing), Managing email addresses and sending messages, Infrastructure monitoring, Remarketing and Behavioral Targeting, Managing support and contact requests, Interaction with support and feedback platforms, Contacting the User, Advertising and Location-based interactions.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

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

These services allow User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, 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 this Application. For more information, please check the privacy policies of the relevant services.

Direct Email Marketing (DEM) (This Application)

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

Personal Data collected: Email.

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

Google Analytics (Google)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

Google AdWords conversion tracking (Google)

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 this Application.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

Google Tag Manager (Google)

Google Tag Manager is an analytics service provided by Google, Inc.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

Google Analytics with anonymized IP (Google)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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.

This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within Member States of the European Union or in other Contracting States to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the USA.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

Display Advertising extension for Google Analytics (Google)

Google Analytics on this Application might use Google's Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

Facebook Ads conversion tracking (Facebook)

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

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

User ID extension for Google Analytics (Google)

Google Analytics on this Application 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 this Application.

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: Cookie.

Place of processing: USA – Privacy PolicyOpt Out

Contact form (This Application)

By filling in the contact form with their Data, the Users authorizes this Application 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: Country, Email, First Name, Last Name, Phone number, Province, State, Various types of Data and ZIP/Postal code.

Mailing List or Newsletter (This Application)

By registering to the mailing list or to 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 this Application. Your email address might also be added to this list as a result of signing up to this Application or after performing a purchase.

Personal Data collected: Email, First Name and Last Name.

Phone contact (This Application)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.

Personal Data collected: Phone number.

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 this Application.

Google Website Optimizer (Google)

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: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them.

If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Maps widget (Google)

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

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

Instagram widget (Instagram, Inc.)

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

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

SoundCloud widget (SoundCloud Limited)

Soundcloud is an audio content delivery service provided by SoundCloud Limited that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Usage Data.

Place of processing: Germany – Privacy Policy

Vimeo video (Vimeo, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data collected: Various types of Data.

Place of processing: USA – Privacy Policy

These services have the purpose of hosting data and files that enable the Application to run and be distributed. Some of these services work through servers geographically distributed, making difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (Amazon)

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

Personal Data collected: Various types of Data.

Privacy Policy

Heroku (Heroku, Inc.)

Heroku is a hosting service provided by Heroku, Inc.

Personal Data collected: Various types of Data.

Place of processing: USA – Privacy Policy

These services allow this Application 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 this Application.

New Relic (New Relic)

New Relic is a monitoring service provided by New Relic Inc.

The way New Relic is integrated means that it filters all traffic of this Application, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Application to be collected.

Personal Data collected: Various types of Data.

Place of processing: USA – Privacy Policy

These services allow Users to interact with third party support and feedback platforms directly from the pages of this Application.

If one of these services is installed, it may collect browsing and usage data in the pages where it is installed, even if the Users do not actively use the service.

Zendesk Widget (Zendesk)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy Policy

Geolocation (This Application)

This Application 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 this Application.

Personal Data collected: Geographic position.

These services make it possible to manage a database of email contacts to communicate with the User via email.

The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the User interacts with incoming mail, such as by clicking on links included in the email.

Mailchimp (Mailchimp)

Mailchimp is an email address management and message sending service provided by Mailchimp Inc.

Personal Data collected: Email.

Place of processing: USA – Privacy Policy

Mandrill (The Rocket Science Group, LLC.)

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

Personal Data collected: Email and Usage Data.

Place of processing: USA – Privacy Policy

These services allow this Application to manage support and contact requests received via email or by other means, such as the contact form.

The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Zendesk (Zendesk)

Zendesk is a support and contact request management service provided by Zendesk Inc.

Personal Data collected: Various types of Data.

Place of processing: USA – Privacy Policy

These services allow this Application and its partners to inform, optimize and serve advertising based on past use of this Application 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.

Remarketing through Google Analytics for Display Advertising (Google)

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: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

AdWords Remarketing (Google)

AdWords Remarketing is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

Twitter Remarketing (Twitter)

Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.

Personal Data collected: Cookie and Usage Data.

Place of processing: USA – Privacy PolicyOpt Out

Further information about Personal Data

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

Information about Cookies

These Cookies are necessary for the functioning of the services filed under the section ”Analytics”.

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Google Analytics Cookies.

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Google Analytics with anonymized IP Cookies.

These Cookies are necessary for the functioning of the services filed under the section ”Infrastructure monitoring”.

JSESSIONID

New Relic Cookies.

Since the installation of third party Cookies and other tracking systems through the services used within this Application can not be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, consult the privacy policy for the respective third party services listed in this document.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User is aware of the fact that the Data Controller 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, this Application 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, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

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

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application 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 Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller erase the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application ), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, 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 this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers to.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning 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 by which the Personal Data of the User is collected.

Cookie

Small piece of data stored in the User's device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to this Application.

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