PRIVATE DATA WE RECEIVE AND COLLECT
Last modified: July 1, 2020
Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
How we use your information
We use the information we collect in various ways, including to:• Provide, operate, and maintain our webste • Improve, personalize, and expand our website • Understand and analyze how you use our website • Develop new products, services, features, and functionality • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the webste, and for marketing and promotional purposes • Send you emails • Find and prevent fraud
Cookies and Web Beaconsss
Google DoubleClick DART Cookie
Our Advertising Partners
Advertising Partners Privacy Policies
Third Party Privacy Policies
CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to: Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers. Request that a business delete any personal data about the consumer that a business has collected. Request that a business that sells a consumer's personal data, not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following: The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service. The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete. The right to erasure – You have the right to request that we erase your personal data, under certain conditions. The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions. The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity. Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Types of Data collected
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 Dhiti.app (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
METHODS 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.
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 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; 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.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. 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 fulfil 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. 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 Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Displaying content from external platforms, Handling payments, Interaction with external social networks and platforms, Contacting the User, Managing contacts and sending messages, Platform services and hosting, RSS feed management and SPAM protection. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”. Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:
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 INC.)
CONTACTING THE USER
MAILING LIST OR NEWSLETTER (DHITI.APP)
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 the Dhiti.app. Your email address might also be added to this list as a result of signing up for the Dhiti.app or after making a purchase. Personal Data processed: address; city; company name; country; email address; first name; last name; phone number; Usage Data; website; ZIP/Postal code.
PHONE CONTACT (DHITI.APP)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Dhiti.app, as well as for fulfilling support requests. Personal Data processed: phone number.
DISPLAYING CONTENT FROM EXTERNAL PLATFORMS
This type of service allows you to view content hosted on external platforms directly from the pages of the Dhiti.app 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.)
YOUTUBE VIDEO WIDGET (GOOGLE INC.)
Payment processing services enable Dhiti.app to process payments by credit card, bank transfer or other means. To ensure greater security, Dhiti.app 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.
PAYPAL (PAYPAL INC.)
INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS
This type of service allows interaction with social networks or other external platforms directly from the pages of Dhiti.app. The interaction and information obtained through Dhiti.app are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on Dhiti.app isn’t being connected back to the User’s profile.
PAYPAL BUTTON AND WIDGETS (PAYPAL INC.)
MANAGING CONTACTS AND SENDING MESSAGES
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.)
PLATFORM SERVICES AND HOSTING
These services have the purpose of hosting and running key components of Dhiti.app, therefore allowing the provision of Dhiti.app from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
BLOGGER (GOOGLE LLC)
RSS FEED MANAGEMENT
This type of service allows Dhiti.app 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.)
This type of service analyzes the traffic of Dhiti.app, 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.)
SELLING GOODS AND SERVICES ONLINE
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 Dhiti.app depends on the payment system used. 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: 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 Dhiti.app depends on the payment system used. 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. 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
ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA
SYSTEM LOGS AND MAINTENANCE
For operation and maintenance purposes, Dhiti.app and any third-party services may collect files that record interaction with Dhiti.app (System logs) use other Personal Data (such as the IP Address) for this purpose
INFORMATION NOT CONTAINED IN THIS POLICY
For operation and maintenance purposes, Dhiti.app and any third-party services may collect files that record interaction with Dhiti.app (System logs) use other Personal Data (such as the IP Address) for this purpose.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Dhiti.app 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.
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.
Information collected automatically through Dhiti.app (or third-party services employed in Dhiti.app), which can include: the IP addresses or domain names of the computers utilized by the Users who use Dhiti.app, 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.
The individual using Dhiti.app who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
DATA PROCESSOR (OR DATA SUPERVISOR)
The natural person to whom the Personal Data refers.
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 Dhiti.app. The Data Controller, unless otherwise specified, is the Owner of Dhiti.app.
DHITI.APP (OR THIS APPLICATION)
The means by which the Personal Data of the User is collected and processed.
The service provided by Dhiti.app 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.
Small sets of data stored in the User's device.
Latest update: Nov 12, 2020
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING INFORMATION SHARING
Neuro Insideout LLP only shares personal information with other companies or individuals outside of Neuro Insideout LLP in the following limited circumstances:
* We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
* We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent or otherwise address fraud, security or technical issues or (d) protect against imminent harm to the rights, property or safety of Neuro Insideout LLP, its users or the public as required or permitted by law.
We may share with third parties certain pieces of aggregate non-personal information, this is information that is recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user. Such information does not identify you individually.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.We restrict access to personal information to Neuro Insideout LLP employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
ACCESSING AND UPDATING PERSONAL INFORMATION
When you use Neuro Insideout LLP services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes) or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.