Types of Data collected

Among the types of Personal Data that owlpower.eu collects, by itself or through third parties, there are: Cookies and Usage Data. 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 owlpower.eu’s website, services or apps. Unless specified otherwise, all Data requested by owlpower.eu is mandatory and failure to provide this Data may make it impossible for owlpower.eu to provide its services. In cases where owlpower.eu 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 owlpower.eu or by the owners of third-party services used by owlpower.eu 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 owlpower.eu 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 owlpower.eu (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.

The legal basis of the processing

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

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

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

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

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to 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.

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 the 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, Backup saving and management, Traffic optimization and distribution and SPAM protection. 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. The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Registration and authentication, Access to third party services’ accounts, Analytics, Interaction with support and feedback platforms, Managing support and contact requests, Displaying content from external platforms, Managing contacts and sending messages, Hosting and backend infrastructure, Remarketing and behavioral targeting, Handling payments, Interaction with external social networks and platforms, Interaction with live chat platforms, Infrastructure monitoring, User database management, Commercial affiliation, Tag Management and Data transfer outside the EU.

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:

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 behaviour.

 

Matomo Analytics (originally Piwik) – Matomo Analytics is a web analysis service provided by https://matomo.org/about/. Matomo Analytics utilizes the Data collected to track and examine the use of TOP10LIST, to prepare reports on its activities.

Backup saving and management – This type of service allow the Owner to save and manage backups of owlpower.eu on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to owlpower.eu.

Backup on Google Drive (Google Inc.) – Google Drive is a service to save and manage backups provided by Google Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Traffic optimization and distribution – This type of service allows owlpower.eu to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between owlpower.eu and the User’s browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.

CloudFlare (Cloudflare) – CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc. The way CloudFlare is integrated means that it filters all the traffic through owlpower.eu, i.e., communication between owlpower.eu and the User’s browser, while also allowing analytical data from owlpower.eu to be collected. Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service. Place of processing: United States – 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.

 

Personal Data collected: various types of Data.

Displaying content from external platforms – This type of service allows you to view content hosted on external platforms directly from the pages of owlpower.eu 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 owlpower.eu to incorporate the content of this kind on its pages. Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Gravatar (Automattic Inc.) – Gravatar is an image visualization service provided by Automattic Inc. that allows owlpower.eu to incorporate the content of this kind on its pages. Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service. Personal Data collected: email address and Usage Data. Place of processing: United States – Privacy Policy.

 

Further information about Personal Data

Analysis and predictions based on the User’s Data (“profiling”) – The Owner may use the Personal and Usage Data collected through owlpower.eu 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.

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. owlpower.eu 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. owlpower.eu 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 security related and based on algorithms subject to predefined criteria – which may also be provided by third parties. The rationale behind the automated decision making is:

• 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 owlpower.eu, 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.

Personal Data collected through sources other than the User – The Owner of owlpower.eu may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing. Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

 

Further rights of the Users – We don’t sell or rent Users’ Data, to any third parties, for any purpose. The only uses of Data are those highlighted in this policy. Users are the only owner of their own Data and can request modification or deletion at any time.

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 the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing – Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

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

Additional information about Data collection and processing

Legal action – The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of owlpower.eu 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, owlpower.eu 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, owlpower.eu and any third-party services may collect files that record interaction with owlpower.eu (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 – owlpower.eu actively and fully supports “Do Not Track” based on requesting browsers. To determine whether any of the third-party services it uses honour 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 owlpower.eu 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.

Cookie Policy – owlpower.eu uses MINIMAL Cookies, the so called “Necessary cookies”. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

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 owlpower.eu, if not stated otherwise within this document.