Privacy policy

Data Controller


Name: Andrea Piccioni


Fiscal Code: 01961220561


Address: Via Cassia Cimina 517 - 01037 - Ronciglione (VT)


Email: framedrums@gmail.com


Type of Data Collected


Among the Personal Data collected by this Application, independently or through third parties, are: Email, First Name, Last Name, Cookie, Usage Data, Phone Number, Profession, Province, Country, Zip Code, Birth Date, City, Address, Business Name, Website, various types of Data, Sex, VAT Number, Tax Code, Business Sector, User ID, Geographic Location, Image, About Me, Data disclosed during the use of the service, Username, Camera Permission and unique identifiers of devices for advertising (for example: Google Advertiser ID or IDFA identifier).
Other Personal Data collected may be indicated in other sections of this privacy policy or through information texts displayed at the same time as the collection of the Data. 
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be entered voluntarily by the User, or collected automatically during the use of this Application.
Unless otherwise specified, all data requested by this application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who are unsure of what Data is mandatory are encouraged to contact the Data Controller. 
Any use of Cookies - or other tracking tools - by this Application or the owners of third party services used by this Application, unless otherwise specified, is intended to identify the User and record their preferences for purposes strictly related to providing the service requested by the User. 
Failure by the User to provide certain Personal Data may prevent this Application from providing its services.
The User assumes responsibility for the Personal Data of third parties published or shared through this Application and guarantees that he/she has the right to communicate or disseminate them, releasing the Owner from any liability towards third parties. 

Method and place of processing of the collected data
Processing Methods


The Data Controller processes Users' Personal Data by taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. 
The treatment is carried out through computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, the Data may be accessed by categories of employees involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can 


Legal Basis of Data Processing


The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
- the User has given consent for one or more specific purposes. Note: in some jurisdictions, the Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opts out") of such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data; 
- the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
- the processing is necessary to comply with a legal obligation to which the Controller is subject; 
- the processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Data Controller; 
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract. 

Location 


The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. 
Your Personal Data may be transferred to a country other than the country in which you are located. For further information on the location of processing, please refer to the section on Personal Data processing details. 
The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the UN, as well as about the security measures adopted by the Data Controller to protect the Data. 
In the event that one of the transfers just described takes place, the User may refer to the respective sections of this document or request information from the Controller by contacting him at the contact details given at the beginning. 


Retention Period 


Data are processed and stored for the time required by the purposes for which they were collected.
Accordingly: 
Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the execution of such contract is completed. 
Personal Data collected for purposes attributable to the legitimate interest of the Controller will be retained until such interest is satisfied. You may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller. 

When processing is based on Your consent, the Controller may retain Personal Data for longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. 
At the end of the storage period, the Personal Data will be deleted. Therefore, at the end of this period the right of access, cancellation, rectification and the right to data portability can no longer be exercised. 


Purposes of Data Processing 


User Data is collected to enable the Owner to provide its Services, as well as for the following purposes: Accessing accounts on third party services, Contacting the User, Managing contacts and sending messages, Managing payments, Managing support and contact requests, Hosting and backend infrastructure, Commenting on content, Social features, Managing tags, Statistics, 

Interaction with social networks and external platforms,

Heat mapping and session recording,

Interaction with live chat platforms,


Interaction with support and feedback platforms, Location-based interactions, Permission to access Personal Data on the User's device, SPAM protection, Advertising, Registration and authentication, Remarketing and behavioral targeting, Content and feature performance testing (A/B testing), Data transfer outside the EU and Viewing content from external platforms. 
To obtain further detailed information on the purposes of processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document. 


Facebook Permissions Required by this Application 


This Application may require certain Facebook permissions that allow it to perform actions with the User's Facebook account and collect information, including Personal Data, from it. This service allows this Application to connect with the User's account on the social network Facebook, provided by Facebook Inc. 
For more information on permissions below, please refer to Facebook's permissions documentation and privacy policy


Basic Information


The basic information of the User registered on Facebook which normally includes the following Data: Id, Name, Image, Gender and Language and in some cases Facebook "Friends". If the User has made additional Data publicly available, the same will be available. 


Personal Data Processing Details 


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

Access to accounts on third party services


These types of services allow this Application to take Data from your accounts on third party services and perform actions with them. 
These services are not activated automatically, but require the express permission of the User. 


Content Commentary 


The comment services allow Users to formulate and publish their comments on the content of this Application. 
The Users, depending on the settings decided by the Owner, can also leave the comment in anonymous form. If the Personal Data provided by the User includes email, this may be used to send notifications of comments on the same content. Users are responsible for the content of their comments. 
If a comment service provided by a third party is installed, it is possible that, even if the Users do not use the comment service, it collects traffic data relating to the pages where the comment service is installed. 


Contact User 


Contact by phone (this Application) 


Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Application, as well as to fulfill support requests. 
Personal Data Collected: Phone Number


Contact Form (this Application)


The User, by filling out the contact form with his or her data, consents to the use of such data for the purpose of responding to requests for information, quotes, or any other purpose indicated in the header of the form. 
Personal Data collected: Zip Code, City, Tax Code, Last Name, Date of Birth, Email, User ID, Address, Country, Name, Phone Number, VAT Number, Profession, Province, Business Name, Gender, Industry, Website, and various types of Data. 


Contact and Message Manager


This type of service makes it possible to manage a database of email contacts, telephone contacts or contacts of any other type used to communicate with the User. 
These services may also allow the collection of data relating to the date and time of viewing of messages by the User, as well as the User's interaction with them, such as information on clicks on links included in messages. 


Mailgun (Mailgun, Inc.)


Mailgun is an address management and email delivery service provided by Mailgun, Inc. 
Personal Data Collected: Last Name, Cookies, Date of Birth, Usage Data, Email, Address, Country, First Name, Phone Number, Profession, Gender and various types of Data. 
Place of processing: United States - Privacy Policy


Hosting and Backend Infrastructure 


This type of service has the function of hosting data and files that allow this application to function, allow its distribution and provide a ready-to-use infrastructure to provide specific functionalities of this application. 
Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored. 


Google Cloud Storage (Google Ireland Limited)


Google Cloud Storage is a hosting service provided by Google Ireland Limited.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland -Privacy Policy . Privacy Shield Adherent. 


Interaction with Live Chat Platforms


This type of service allows the User to interact with live chat platforms, managed by third parties, directly from the pages of this Application. This allows the User to contact the support service of this Application or this Application to contact the User while he/she is browsing its pages. 
In case a service for interaction with live chat platforms is installed, it is possible that, even if Users do not use the service, it collects Usage Data related to the pages where it is installed. Moreover, live chat conversations may be recorded. 


Interaction with Social Networks and External Platforms 


This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this Application. 
The interactions and information acquired by this Application are in any case subject to the privacy settings of the User relating to each social network. 
If a service for interaction with social networks is installed, it is possible that, even if Users do not use the service, it will collect traffic data relating to the pages where it is installed. 


Facebook "Like" Button and Social Widgets (Facebook, Inc.) 


The Facebook "Like" button and social widgets are Facebook social network interaction services, provided by Facebook, Inc. 
Personal Data Collected: Cookies and Usage Data. 
Place of processing: United States -Privacy Policy . Privacy Shield Adhering Party. 


YouTube Button and Social Widgets (Google Ireland Limited) 


The YouTube social button and widgets are services for interaction with the YouTube social network, provided by Google Ireland Limited. 
Personal Data Collected: Usage Data. 
Place of Processing: Ireland -Privacy Policy. Privacy Shield Adherent. 


Location-Based Interactions
Non-continuous geolocation (this Application) 


This Application may collect, use and share Data relating to the User's geographical location in order to provide location-based services. 
Most browsers and devices provide by default tools to deny geographical tracking. If the User has expressly authorized this possibility, this Application may receive information on his or her actual geographical location. 
The geographic localization of the User takes place in a non continuous manner, upon specific request of the User or when the User does not indicate in the appropriate field the place where he is and allows the application to automatically detect the position. 
Personal Data Collected: Geographic Location. 


SPAM Protection 


This type of service analyzes the traffic of this Application, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM. 


Google reCAPTCHA (Google Ireland Limited) 


Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
Use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.
Personal Data Collected: Cookies and Usage Data. 
Place of Processing: Ireland - Privacy Policy.Privacy Shield Adherent. 


Registration and Authentication 


By registering or authenticating, the User allows the Application to identify him/her and give him/her access to dedicated services. 
Depending on what is set forth below, registration and authentication services may be provided with the help of third parties. If this occurs, this application may access some Data stored by the third party service used for registration or identification. 


Statistics


The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior. 


Data Transfer Outside the EU


The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all non-EU countries) only in accordance with a specific legal basis. Therefore, such transfers of Data are performed in accordance with one of the legal bases described below 
The User may request information from the Controller regarding the legal basis concretely applicable to each individual service. 


Transfer to Third Countries on the Basis of Standard Contractual Clauses (this Application) 


Where this is the legal basis, transfers of Personal Data from the EU to third countries are made on the basis of standard Personal Data protection clauses adopted by the European Commission. 
In such cases, the recipients of the Data have agreed to process the Personal Data in accordance with the levels of protection provided by the legislation. Users may request further information by contacting the Data Controller at the contact details indicated in this document. 

Transfer to Third Countries Based on Consent (this Application) 


When this is the legal basis, the transfer of Personal Data from the EU to third countries occurs only when the User has expressly consented to such transfer after having been informed about the risks due to the absence of an adequacy decision and the appropriate safeguards adopted 
In such cases, the Data Controller informs Users and collects their consent through this Application.
Personal Data Collected: Various Types of Data. 


Data Transfer to Countries that Guarantee European Standards (this Application) 


When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision adopted by the European Commission. The European Commission adopts adequacy decisions with respect to individual third countries that it deems to ensure a level of protection of Personal Data comparable to that provided by European legislation on the protection of Personal Data. You can view the updated list of adequacy decisions on the European Commission's website. 
Personal Data Collected: Various Types of Data. 


Transfer of Data from the EU and/or Switzerland to the United States based on the Privacy Shield (this Application) 


When this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the United States occurs under the EU-US or Switzerland-US Privacy Shield agreement. 
In particular, Personal Data is transferred to entities that have self-certified under the Privacy Shield and therefore ensure an adequate level of protection for the transferred Data. The services affected by the transfer of Data are listed in the respective sections of this document. Among them, those that adhere to the Privacy Shield can be identified by consulting the relevant privacy policy or by checking the status of their registration in the official list of the Privacy Shield. 
The rights of Users under the Privacy Shield are described in an updated form on the website of the United States Department of Commerce.
The transfer of Personal Data from the EU or Switzerland to the United States to entities that are not (no longer) Privacy Shield members is only permissible under another valid legal basis. Users may request information from the Controller regarding such legal bases. 
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 this Application and to interact with them. 
In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.


Google Fonts (Google Ireland Limited)


Google Fonts is a font display service operated by Google Ireland Limited that allows this Application to integrate such content into 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 Adherent. 


Widget Google Maps (Google Ireland Limited) 


Google Maps is a map visualization service managed by Google Ireland Limited that allows this Application to integrate such contents within its pages.
Personal Data Collected: Cookies and Usage Data. 
Place of Processing: Ireland -Privacy Policy Privacy Shield Adherent. 


YouTube Video Widget (Google Ireland Limited)


YouTube is a video content viewing service managed by Google Ireland Limited, which allows this Application to integrate such content into its pages. 
Personal Data Collected: Cookies and Usage Data. 
Place of processing: Ireland -Privacy Policy. Privacy Shield Adherent. 


YouTube Video Widget without Cookies (Google Ireland Limited) 


YouTube is a video content viewing service managed by Google Ireland Limited that allows this Application to integrate such content within its pages.
This widget is set up so that YouTube does not save information and cookies about Users on this Application, unless they play the video.
Personal Data Collected: Usage Data. 
Place of Processing: Ireland - Privacy Policy. Privacy Shield Adherent. 


User Data Analysis and Forecasting ("profiling") 


The Owner may process the usage data collected through this Application to create or update user profiles. This type of treatment allows the Owner to evaluate the choices, preferences and behavior of the User for the purposes specified in the respective sections of this document.

User profiles can also be created thanks to automated tools, such as algorithms, which can also be offered by third parties. To obtain further information on the profiling activity, the User may refer to the respective sections of this document.
The User has the right to object to this profiling activity at any time. To find out more about the User's rights and how to exercise them, the User may refer to the section of this document relating to Users' rights.


Personal Data Collected from Sources Other Than the User 


The Owner of this Application may have legitimately collected Personal Data relating to the User without the User's involvement, drawing on sources provided by third parties, in accordance with the legal bases described in the section on the legal bases of processing. 
If the Data Controller has collected Personal Data in this way, the User may find specific information regarding the sources in the respective sections of this document or by contacting the Data Controller. 


Sale of Goods and Services Online 


The Personal Data collected is used to provide services to the User or to sell products, including payment and delivery. The Personal Data collected to finalize the payment may be that relating to the credit card, the bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used. 


User Rights 


Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
- withdraw consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed. 
- object to the processing of their Data. You may object to the processing of your Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below. 
-access to their own Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed. 
- verify and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.
- obtain the limitation of the processing. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any purpose other than their preservation. 
-obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller. 
-receive their own Data or have them transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto. 
-propose a complaint. The User may lodge a complaint with the competent da


Details on the Right to Object


When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation. 
Users should note that if their Data is processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document. 

How to Exercise Rights 


In order to exercise the User's rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month. 


Further Information on Personal Data 
Sale of Goods and Services Online 


The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. 
The Personal Data collected to finalize the payment may be those relating to the credit card, the bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used. 


Further Information on the Treatment

Legal Defense


The User's Personal Data may be used for the defense by the Owner in court or in the preparatory stages of its possible establishment, from abuse in the use of the same or related services by the User. 
The User declares to be aware that the Data Controller may be required to disclose the Data upon request of the public authorities.


Specific Information


At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific services, or the collection and processing of Personal Data.


System Log and Maintenance


For operational and maintenance purposes, this Application and any third party services used by it may collect System Logs, i.e. files that record interactions and which may also contain Personal Data, such as the User's IP address. 


Information Not Contained in This Policy 


More information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact information.


Exercise of Rights by Users 


The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or otherwise of such data at the Data Controller, to know its content and origin, to request a copy of all data processed, to verify its accuracy or request its integration, the cancellation of the account and data processed, updating, rectification, transformation into anonymous form or blocking of Personal Data processed in violation of the law, and to oppose in any case, for legitimate reasons, their treatment. Requests should be addressed to the Data Controller. 

For any request on the processing of your data on andreapiccioni.net write us at framedrums@gmail.com. This Application does not support "Do Not Track" requests. To find out whether any third party services used support them, please consult 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 advertising it to Users on this page. Therefore, please consult this page often, taking as reference the date of last modification indicated at the bottom. In case of non-acceptance of the changes made to this privacy policy, the User must cease using this Application and may request the Data Controller to remove his/her Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected up to that moment. 


About this Privacy Policy 


The Data Controller is responsible for this privacy policy, drafted from forms prepared by Iubenda and stored on its servers. 

Definitions and Legal References




Personal Data (or Data)


Personal data is any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number. 


Usage Data


This is the information collected automatically by this Application (or by third party applications that this Application uses), including: IP addresses or domain names of computers used by the User who connects to this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment. 


User


The individual who uses this Application, who must coincide with or be authorized by the Data Subject and whose Personal Data is being processed. 


Interested


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


Data Processor (or Manager)




The natural person, the legal person, the public administration and any other body, association or organization appointed by the Data Controller for the processing of Personal Data, in accordance with the provisions of this privacy policy. 


Data Controller (or Owner)


The natural person, legal entity, public administration and any other body, association or organization that is responsible, also jointly with another owner, for decisions regarding the purposes, methods of processing personal data and the tools used, including the security profile, in relation to 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 through which the Personal Data of Users are collected.


Cookies


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


Legal References 


This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679. 
This privacy policy applies exclusively to this Application. 


Legal References 


This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679. 
This privacy policy applies exclusively to this Application. 


Contact


If you have any questions regarding this Privacy Policy, please contact us at framedrums@gmail.com.



Date of last revision:07/07/2021