Privacy Policy of www.Coolwick.com

This Website collects some Personal Data from its Users.

Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

Owner and Data Controller

Coolwick.com, 16615 US-19, Hudson, FL 34667 US

Owner contact email: support@Coolwick.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; email address; various types of Data; first name; last name; phone number; Data communicated while using the service; address; username; password; country; state; province; ZIP/Postal code; city; billing address; shipping address; house number; data relating to the point of sale.

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 this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 this Website or by the owners of third-party services used by this Website 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 this Website 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 this Website (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.

If broader protection standards are applicable, 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, Advertising, Managing contacts and sending messages, Contacting the User, Commercial affiliation, Content commenting, Content performance and features testing (A/B testing), Displaying content from external platforms, Handling payments, Infrastructure monitoring, Interaction with live chat platforms, Registration and authentication and Remarketing and behavioral targeting.

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.

Detailed information on the processing of Personal Data

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

Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, 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 Website. 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.

Google AdSense (Google Inc.)

Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.

Personal Data collected: Cookies; Usage Data.

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

Analytics

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 with anonymized IP (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 this Website, 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 US.

Personal Data collected: Cookies; Usage Data.

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

Yahoo Advertising conversion tracking (Yahoo! Inc.)

Yahoo Advertising conversion tracking is an analytics service provided by Yahoo! Inc. that connects data from the Yahoo advertising network with actions performed on this Website.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data collected: Cookies; Usage Data.

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

Google Ads conversion tracking (Google Inc.)

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

Personal Data collected: Cookies; Usage Data.

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

Display Advertising extension for Google Analytics (Google Inc.)

Google Analytics on this Website 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: Cookies; Usage Data.

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

Commercial affiliation

This type of service allows this Website to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
For details of which data are collected, please refer to the privacy policy of each service.

ShareAsale (ShareAsale.com Inc.)

ShareAsale is a banner commercial affiliation service provided by ShareAsale.com Inc.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Contacting the User

Mailing list or newsletter (this Website)

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 this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

Personal Data collected: Cookies; email address; first name; last name; Usage Data.

Contact form (this Website)

By filling in the contact form with their Data, the User authorizes this Website 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.

Phone contact (this Website)

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

Personal Data collected: phone number.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Website.
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 (this Website)

This Website has its own internal content comment system.

Personal Data collected: email address; first name; last name.

Content performance and features testing (A/B testing)

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 Website.

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; Usage Data.

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

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website 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 this Website to incorporate content of this kind on its pages.

Personal Data collected: Usage Data; 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 this Website to incorporate content of this kind on its pages.

Personal Data collected: Cookies; Usage Data.

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

Handling payments

Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website 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.)

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.

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.

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: Cookies; email address; first name; last name; various types of Data.

Place of processing: United States – Privacy Policy.

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: Cookies; email address; first name; last name; Usage Data.

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

Registration and authentication

By registering or authenticating, Users allow this Website 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, this Website will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Direct registration (this Website)

The User registers by filling out the registration form and providing the Personal Data directly to this Website.

Personal Data collected: address; billing address; city; country; data relating to the point of sale; email address; first name; house number; last name; password; phone number; province; shipping address; state; username; various types of Data; ZIP/Postal code.

Remarketing and behavioral targeting

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website 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.

Google Ads Remarketing (Google LLC)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.

Personal Data collected: Cookies; Usage Data.

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

Further information about Personal Data

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 this Website depends on the payment system used.

The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use this Website only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Website.

Automated decision-making

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. This Website 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. This Website 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 this Website, 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.

Analysis and predictions based on the User’s Data (“profiling”)

The Owner may use the Personal and Usage Data collected through this Website to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

The rights of Users

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

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

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.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

• is performed by an Owner based within the EU;
• concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
• concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Cookie Policy

This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

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 this Website 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, this Website 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 Website and any third-party services may collect files that record interaction with this Website (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

This Website 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 this Website 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 this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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 Website 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 this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

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

Service

The service provided by this Website 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 this Website, if not stated otherwise within this document.

Latest update: July 30, 2019