We live in a data-driven world. Almost every transaction and interaction you have with most organizations involves sharing personal data such as your name, address, and date of birth. You also share data online every time you visit a website, search or purchase something, use social media, or send an email.

Data sharing helps make life easier, more convenient, and connected. But your data is your data. It belongs to you, so it's important that your data is used only in ways you would reasonably expect and that it remains secure. Data protection laws ensure that everyone's data is used correctly and legally.

You can visit our website without actively providing personal information. In this case, we will technically process the following personal data:

a. Technical provision of the website

In order to technically provide the website, it is necessary for us to process information related to you to ensure that your browser can display our website and that you can use it. This information is automatically transmitted each time you visit our website and is saved in the log files of our servers. It pertains to the computer system of the device from which the visit is made. The following information is collected:

• IP address, assigned by your provider to your device during the connection
• Date and time of access
• How you reached the website (previous page, hyperlink)
• Amount of data sent
• Which browser and browser version you used
• Operating system of the device you used
• Which internet service provider you used

These data are also necessary for us to optimize our website and ensure the security of our IT systems. For this reason, the data is temporarily stored as a technical measure.

Furthermore, we employ necessary technical cookies to provide you with our website and its technical functions. Additionally, with your consent, we use other types of cookies as described in detail in our Cookie Policy, which we invite you to visit.

We process personal data for the technical provision of our website based on the following legal grounds:

• For the fulfillment of a contract or the implementation of pre-contractual measures in accordance with Article 6(1)(b) of the GDPR, if you visit our website to inquire about our products and services.
• For the protection of our legitimate interests in accordance with Article 6(1)(f) of the GDPR, in order to ensure the stability and functionality of our website.

b. Statistical analysis of website usage

In order to improve the quality of our website and its content, we use analysis tools. They allow us to understand how and to what extent the website is used, and we can continuously optimize our offerings. We process your personal data for statistical analysis of the usage of our website based on your consent, Article 6(1)(a) of the GDPR.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA, on our website. Google Analytics uses "cookies," which are text files stored on your device that enable an analysis of website usage. On our website, Google Analytics is configured with IP anonymization enabled to ensure the anonymous recording of IP addresses (referred to as "IP masking"). This means that your IP address is abbreviated within the European Union or in other states that are part of the Agreement on the European Economic Area before being transferred to Google. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and abbreviated there. The IP address transmitted by your browser during the use of Google Analytics will not be associated with other data from Google. Further information on the terms of use and data protection can be found on the website https://policies.google.com. On our behalf, Google will use this information for the purpose of tracking and examining your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage.

The legal basis for using Google Analytics is your consent, Article 6(1)(a) of the GDPR.

You can revoke your consent at any time in our Cookie Center section.

Furthermore, you can prevent the collection of data generated by the cookie and related to your use of the website and the processing of this data by Google by downloading and installing the browser plugin available at https://tools.google.com/dlpage/gaoptout. Opt-out cookies prevent the future collection of your data when visiting this website. To prevent data collection by Google Analytics across different devices, you must opt-out on all systems used.

c. Online marketing

In order to improve our marketing on search engines such as Google and Bing, and our advertising activities on social media platforms such as LinkedIn and Facebook, we use services provided by the respective third parties. These services allow us to evaluate the effectiveness of our advertising campaigns and create personalized and interest-based advertising offers for users.

Google Ads Conversion Tracking

Our website uses the "Google Conversion Tracking" tool as part of the Google Ads online advertising program, a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you click on an ad placed by Google, a so-called Conversion-Tracking Cookie will be stored on your device. This cookie remains active for 30 days and does not contain personal data, so we cannot personally identify you. The information collected with the conversion cookie is used to compile conversion statistics and determine the total number of users who clicked on our ad and were redirected to our website. This allows us to identify which advertising initiatives are particularly effective. We do not receive any additional data, and in particular, we cannot identify users based on this information. To deactivate participation in Google Ads Conversion Tracking, you need to disable the storage of tracking cookies in the corresponding settings of your browser. In this case, you will not be included in our Conversion Tracking statistics.

The legal basis for this data processing is Article 6(1)(a) of the GDPR.

You can modify your consent at any time from our Cookie Center section.

Google Ads Remarketing

Our website uses the features of Google Ads Remarketing, a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to promote our website in Google search results as well as on third-party websites. For this purpose, Google places a cookie in your browser that automatically enables advertising according to your interests, based on the pages you have visited, using a pseudonymous cookie ID. Any further data processing will only take place if you have consented to Google linking your Internet browsing history and Google application data to your Google account and using the information from that account to personalize the ads you see on the web. If you are logged into Google during your visit to our website, Google will use your data along with Google Analytics and Google Ads data to create and define target audience lists for cross-device remarketing. For this purpose, Google temporarily links the personal data of page visitors with Google Analytics and Google Ads data to form the target groups. You can permanently disable the setting of cookies for ad preferences by installing the browser plugin available at the following link: https://www.google.com/settings/ads/onweb/.

The legal basis for this data processing is Article 6(1)(a) of the GDPR.

You can modify your consent at any time from our Cookie Center section.

LinkedIn Insight Tag

Our website uses the "LinkedIn Insight Tag" conversion tool provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. This tool sets a cookie on your device that allows the collection of data, including IP address, device and browser properties, and site activities (e.g., page views). However, these data are encrypted, anonymized within seven days, and the anonymized data will be deleted within 90 days. LinkedIn does not share any personal data with us when using the "LinkedIn Insight Tag" and any related tools but only provides anonymized reports on the audience and advertising performance of the site. We may also conduct retargeting through the LinkedIn Insight Tag. This allows us to display targeted advertisements outside of our website without identifying the user as a visitor to the site.

The legal basis for this data processing is Article 6(1)(a) of the GDPR.

If you have a LinkedIn account, you can use your account settings to manage the use of your personal data for advertising purposes. You can modify your consent at any time from our Cookie Center section.

Facebook Pixel, Custom Audience, and Facebook Conversion

Our website uses the so-called "Facebook pixel" provided and managed by Meta Platforms Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, and if you reside in Europe, by Meta Platforms Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The Facebook pixel allows us to define users of our website as a target group for displaying ads. We use the Facebook pixel in such a way that the ads we activate on Facebook (Facebook Ads) are only visible to users who have shown interest in our website or who have specific characteristics, such as an interest in topics related to digital marketing, which we communicate to Facebook (Custom Audience). In this regard, we may share your encrypted email to allow Facebook to identify you when you log in to the platform. By using the Facebook pixel, we also want to ensure that our ads on Facebook correspond to the potential interests of users. Finally, with the use of the Facebook pixel, we want to evaluate the effectiveness of our advertising activities on Facebook by determining whether users have been directed to our website after clicking on a Facebook ad (Conversion).

The legal basis for this data processing is Article 6(1)(a) of the GDPR.

You can object to the use of Facebook Website Custom Audiences on the page https://www.facebook.com/ads/website_custom_audiences. You can modify your consent at any time from our Cookie Center section.

d. Social Network Plugins

Our website incorporates plugins and/or buttons to allow easy sharing of content on certain social networks. These plugins are programmed in such a way that no cookies are set when accessing the page. Only when you click the button, the respective social network is informed about the visit to our website. Additionally, data such as IP address, date/time of the request, and content of the request are transferred. The activation of the plugin means that your personal data is transferred to the provider and stored there (if US providers are involved, in the United States). Since the provider collects data, particularly through cookies, it is recommended to delete all cookies via the browser's security settings before clicking the button. Please note that if you visit our website while logged into the social network, it may track your visit to our website and associate it with your social network account. By logging out of the social network pages and deleting the set cookies, you can prevent social networks from associating the collected information about you with your account on the respective social network during your visit to our website. If you do not want social networks to directly associate the data collected through our web presence with your profile, you must log out of the respective social network before visiting our website.

The legal basis for this data processing is Article 6(1)(a) of the GDPR, our legitimate interest in obtaining the maximum possible visibility in social media.

e. YouTube Videos

Our website incorporates components (videos) from YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, a company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA. We use the "extended data protection mode" provided by YouTube. According to YouTube, this mode means that YouTube does not store any information about visitors to this site before they watch the video. However, the disclosure of data to YouTube's partners is not necessarily excluded by the extended data protection mode. Thus, YouTube - regardless of whether you watch a video - establishes a connection to the Google DoubleClick network. As soon as you start a YouTube video on this site, a connection to YouTube's servers is established. This informs the YouTube server about which of our pages you have visited. If you are simultaneously logged into your YouTube account, this information will be associated with your YouTube account. You can prevent the transmission of this data by logging out of your account before visiting our site.

In addition, YouTube may store various cookies on your device after starting a video or use comparable recognition technologies. In this way, YouTube can obtain information about visitors to this site. This information is used, among other things, to collect video statistics, improve user experience, and prevent fraud attempts.

The legal basis for this data processing is Article 6(1)(a) of the GDPR. YouTube is used in the interest of an appealing presentation of our online offers.

f. Google Fonts

Our website uses Google Fonts to display external fonts consistently. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To enable the display of certain fonts on our website, a connection to the Google server in the United States is required whenever our website is accessed. Google may identify the website from which the request was sent and to which IP address the fonts are transmitted for display. Through certification under the EU-US Privacy Shield, Google ensures that it will comply with EU data protection regulations when processing data in the United States.

The legal basis is Article 6(1)(f) of the GDPR; our legitimate interest lies in the optimization and cost-effective management of our website.

g. Links to Third-Party Websites

Our website contains links to other websites or services. We are not responsible for the privacy practices of such sites and services. Therefore, we encourage you to exercise caution when leaving our site and to review the privacy statements of each visited site and service before providing your personal data. This Privacy Policy does not apply to such third-party websites and services accessible via links.

2. Active Use of the Website

In addition to purely informational use, you can also actively use our website to contact us, subscribe to the newsletter, or participate in games and quizzes.

a. Contact Requests

In order to process and respond to your requests, such as through the contact forms on the website, we process the personal data you have provided to us in this context. These data always include your name, surname, and email address, so that we can send you a response, as well as any other information you have submitted to us as part of the notification.

We process your personal data to respond to inquiries based on the following legal basis:

• for the protection of our legitimate interests under Article 6(1)(f) of the GDPR; our legitimate interest is in adequately responding to requests from potential customers or other interested individuals.

b. Newsletter

As part of our services, we offer you the opportunity to subscribe to our newsletter. To ensure that no errors occur when entering your email address and to verify that you are the requester, we use the so-called Double-Opt-In procedure. After entering your email address in the registration field, indicating a role (understood as interest or specialization), and giving consent to receive our newsletter, we will send you a confirmation link to the provided email address. Only by clicking on this confirmation link will your email address be added to our mailing list for sending our newsletter.

The legal basis for this data processing is Article 6(1)(a) of the GDPR. Providing data for this purpose is optional. If you do not wish to provide your data, we will not be able to keep you updated on our initiatives, provide you with useful news, and send you personalized offers. You can revoke your consent at any time and without specifying reasons. The easiest way to do this is by clicking on the "Unsubscribe" link, which is included in every newsletter or communication you receive. Alternatively, you can write to privacy@blacktrend.com.

In our newsletters, we use technologies that allow us to measure interactions with the newsletter (e.g., email openings, clicked links). We use this data for general statistical evaluations, as well as to optimize and further develop our content and communication with subscribers. This is done through a small graphic embedded in the newsletter (called pixels).

The legal basis for this statistical analysis is our legitimate interest under Article 6(1)(f) of the GDPR. If you do not wish to receive user behavior analysis, you can unsubscribe from the newsletter or disable the graphics in your email program by default.

c. Spontaneous Email Submissions

When you spontaneously send an email to one of the email addresses indicated on our website, we acquire the sender's email address and any other personal data you have included in the message and attachments in order to fulfill your request. The email boxes corresponding to the addresses indicated on our website are not of a personal nature. They belong to the organizational structure of the company and have the primary purpose of enabling the effective conduct of our business activities. This means that messages forwarded to our email boxes may be accessed by all authorized persons who have access to those boxes. By sending emails to the email addresses indicated on our website, you declare that you have read and accepted the processing conditions contained in this policy.

Your data may be processed by categories of individuals belonging to the organizational structure of the Data Controller and involved in the management of the website (administrative, commercial, marketing, customer service, system administrators).

Your personal data will not be disclosed, but may be processed on behalf of the Data Controller by external parties designated as Data Processors according to Article 28 of the GDPR, to whom appropriate operational instructions are given, such as:

• companies providing website and IT systems maintenance services
• companies providing email delivery and SMTP services
• companies providing hosting and CDN services

1. Informational use of the website

In the case of purely informational use of our website, we save your personal data as follows:

• Server logs will be saved for a period of up to 3 months.
• The duration of storage for employed cookies can be found in the Cookie Policy. Additionally, you have the option to personally delete installed cookies at any time.

2. Active use of the website

In the case of active use of our website, we will only save your personal data for the necessary time:

• Data transmitted in the context of requests will be initially saved for the time necessary to respond to the request and will be deleted after 1 year from the date of submission.
• In the case of newsletter subscriptions, your data will be saved until you request to stop receiving it (withdrawal of consent or objection to receiving it).

The Data Controller may retain the data to fulfill legal obligations or to establish, exercise, or defend its own rights in legal proceedings. Once the purposes for which the data have been collected and processed have been achieved, the Data Controller will take appropriate measures to anonymize them, thus preventing your identification. However, the possibility of continuing to use the data in anonymous form remains.

We protect your personal data with specific technical and organizational security measures aimed at preventing your personal data from being used unlawfully or fraudulently. Additionally, we periodically monitor our systems to identify potential vulnerabilities and cyber attacks.

Despite the measures and efforts we put in place, we cannot guarantee and do not warrant the absolute protection and security of users' personal data. As preventive measures, we urge you to avoid providing us with sensitive personal information and to ensure that your device is equipped with constantly updated antivirus tools. Furthermore, ensure that your internet service provider guarantees the secure transmission of data through firewalls, anti-spam filters, and similar measures.

Our website may share some of the collected data with services located outside the European Union. Specifically, with Google, Facebook, and Microsoft (LinkedIn) through social plugins and the Google Analytics service.

The aforementioned companies ensure their adherence to the Privacy Shield and, when choosing these tools, we verify that the same protections described by European regulations are applied or that they comply with the legal frameworks related to the transfer of data under the EU-US Privacy Shield Framework.

Data will never be transferred to third countries that do not comply with the conditions provided in Article 45 and following of the EU Regulation.

You can exercise your rights guaranteed by law regarding your personal data by writing to the data controller. We will respond to your request as soon as possible and in any case no later than 30 days from the receipt of your notification.

• Right to access (Article 15 of the GDPR): You can ask us whether personal data concerning you is being processed and, if so, obtain a copy of that data and be informed about: the origin of the data; the categories of personal data processed; the recipients of the data; the purposes of the processing; the existence of automated decision-making, including profiling; the retention period of the data; the rights provided by the Regulation.
• Right to rectification (Article 16 of the GDPR): If your data is incomplete or inaccurate, you can request their correction or completion at any time.
• Right to erasure (Article 17 of the GDPR): You can request the deletion of your personal data if they are no longer necessary for the purposes for which they were collected or if we are no longer authorized to process them.
• Right to restriction of processing (Article 18 of the GDPR): You can request the restriction of the processing of your data if you contest their accuracy, for a period that allows us to verify the accuracy of the data; if we are not authorized to process your data and, instead of deleting it, you can request that we limit its use; if we no longer need the data for the intended purpose, but you still need the data to assert or defend legal claims, or you have objected to the data processing.
• Right to data portability (Article 20 of the GDPR): If we process your data based on your consent or for the performance of a contract, or if the processing is carried out by automated means, you can exercise the right to data portability. You can receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. You can also request that your data be transmitted directly to another company, where technically feasible.
• Right to object (Article 7, paragraph 3 of the GDPR): You can object at any time to the processing of your personal data based on our legitimate interests, including profiling.

If you believe that we are processing your data in violation of data protection laws, please contact us so that we can address any concerns. If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with one of the competent supervisory authorities for compliance with the rules on the protection of personal data. In Italy, the complaint can be filed with the Garante per la Protezione dei Dati Personali (http://www.garanteprivacy.it/).

The Data Controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.

Regarding this website, the Data Controller is Blacktrend, srl VAT IT02281611208 with registered office at Via S. Mamolo, 76 - 40136 Bologna.

For any clarification, question, or need related to your privacy and the processing of your personal data, you can write to privacy@blacktrend.com

If you have any questions about data protection, you can also contact our Data Protection Officer (DPO) at any time using your preferred method:

• Blacktrend, srl Attn: DPO Via S. Mamolo, 76 - 40136 Bologna
• email: dpo@blacktrend.com
• tel: +39 051 2750032

The Privacy Policy of the website may be subject to periodic updates. Any substantial changes will be published at this address. We recommend that you periodically monitor this page to stay informed about the validity or modification of these conditions.

Last updated: June 2023