Privacy Policy

This Website collects some Personal Data from its Users.
This document can be printed for reference by using the print command in the settings of any browser.
Owner contact email: michael@socloud.ltd

Types of Data collected

Among the types of Personal Data that this Website collects,
by itself or through third parties, there are: email address; Usage Data; first name; last name; Tracker; website;
Data communicated while using the service; unique device identifiers for advertising (Google Advertiser ID or
IDFA, for example); geographic position; language; username.

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

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.

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 of 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: Handling payments, Registration
and authentication, Managing contacts and sending messages, Traffic optimization and distribution, Contacting the
User, Registration and authentication provided directly by this Website, Displaying content from external
platforms, Tag Management, Managing support and contact requests, Social features and Hosting and backend
infrastructure.

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:

Handling payments

Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via
external payment service providers. In general and unless where otherwise stated, Users are requested to provide

their payment details and personal information directly to such payment service providers. This Website isn't
involved in the collection and processing of such information: instead, it will only receive a notification by the
relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Cookie Policy

This Website uses Trackers. To learn more, 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 notifying 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.

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.