This Privacy & Cookies Policy (“Policy”) dated June 2018 replaces our previous policies. Please take the time to review before you continue to use our products and services.
This Policy applies to any information you provide to us, including through websites, our mobile apps, communications by email and through social media, by telephone and in person. It also covers any information we receive from third parties.
By using our products and services, including browsing our websites, registering or logging in, you agree we may use your information as outlined in this Policy.
If you do not wish to have your information used in line with this Policy, you must not use our products and services and not otherwise provide us with your information.
Information we may hold about you
- Information you’ve provided to us
- Information about products and services you’ve ordered, enquired about or shown an interest in
- Information provided by other companies which have obtained your permission through their own privacy policies to share information about you, including from specialist data companies
- Information about your interaction with our websites, mobile apps and other products and services, including adverts
- Information we collect using cookies stored on your device about your use of our websites and/or selected third party websites
- Information we collect or remember using technologies similar to cookies, such as device identifiers on your mobile device
- Your IP address, which is a number that identifies a specific network device on the internet which allows your device to communicate with websites and apps
- Technical information from your device relating to the service you receive
- Information relating to the location of your device
In line with industry best practice guidelines, we have a central database where we compile and hold all the information we have about our customers. In the industry this is often known as a “single customer view”.
How we may use your information
By using our websites, apps and other products and services, you agree that we may collect, hold, use or otherwise process your information (including personal information) for the purpose of providing you with those products and services and developing our business which shall include (without limitation):
- Verifying your identity (for example when you return to our websites or mobile apps)
- Personalising the content and advertisements you see on our websites and apps
- Developing the design and style of our products and services to make improvements
- Understanding more about you, such as your location and demographic information
- Informing you about the latest changes to our products and services
- Informing you of promotional offers that you might find of interest
- Dealing with, and responding to you about, a comment you have submitted for us or on our message boards, blogs and other such user generated content facilities
- Enabling you to share our content with others
- Customer services and support
- Informing you if you have been successful in any competitions or promotions
- Compiling customer reviews
- Conducting market research
- Carrying out statistical, technical and logistical analysis and strategic development
- Communicating with you in relation to your account or service, service updates or other non-marketing communications
- Communicating (and personalising such communication) with you, according to your preferences
- Sending you periodic newsletters about your chosen services
- Sending you direct marketing. This may include communications by post, telephone or email or SMS about us and our business partners’ products and services, events and special offers
- Maintaining records of our communications with you if you get in contact with us
- Providing you with location based services advertising relevant to your location and previous locations
- Blocking disruptive use and ensuring the security of our products and services
- Ensuring the integrity of votes, competitions and polls
- Complying with laws and other circumstances permitted under the Italian Data Protection Act and other data protection laws
How we may use your information in specific products or services
Message boards, blogs and other public forums
Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information.
Sharing with others
You may only share the details of another person with us where you have their express permission.
Location based services
Where we provide services that utilise your device’s location, such as local offerings, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or WiFi on mobile devices) where you have granted permission for us to access this location information. If you have given us permission to use your location, we may use it for marketing and advertising purposes.
Push and in-app notifications on apps
Where you install one of our apps on your mobile device, this may use push notifications or in-app notifications. These notifications are used for a variety of reasons. For example, push notifications may be used to trigger an automatic download of new content (such as a new edition) or to send you an update message. Please see each app’s download or install page for more information on how they use notifications. Within the app, you may be able to select to receive only certain types of notifications. If you order a product or service from us we may ask for information including your name, e-mail address, delivery and billing address, credit or debit card number and expiry date. Sometimes we may ask for your telephone number to be forwarded to the couriers who may deliver your order. These details allow us to process your orders efficiently.
If you enter a contest or promotion we may ask for your name, address, e-mail address or telephone number. This is so we can run the contest effectively and tell you if you have won.
Social media advertising
We may target advertising on social media sites to specifically include or exclude customers who have registered for our products and services. For example, customers who have an outdated version of our app may see an ad for the latest version, or customers who have already subscribed to our newsletters may not see the ad for those newsletters.
How we may share your information
When you purchase goods or services from us we may partner with specialist companies to fulfil your order. We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. We will use reasonable endeavours to ensure these third parties process your data securely. Sometimes we bring you promotions from other companies. Here the other company will use your information as the data controller in line with their own privacy policies. We may also use your information for marketing purposes as a data controller. We’ll let you know the precise arrangement at the time you provide your personal information. We may share information about you with suppliers that we engage to help us provide the services and/or functionality, e.g. online payment processing. As discussed above, we may share your personal information with other companies within the FCE GROUP of companies. We may also share personal information about you to third parties, where you have given us permission or where the third party can confirm that they have your permission for us to do this. We may also provide third parties with certain aggregate statistical data about our customers’ use of our websites and apps, which may include demographic data such as age range and/or geographic location of groups of our customers. This aggregate data does not include contact details (such as the customer’s name, address or email address). We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business. We may also share your information as required by law and as contemplated by the Italian Data Protection Act and other data protection laws.
Safeguards and security for your information
We have measures in place to protect the security of your personal information from unauthorised access or use, such as by using encryption technology. We comply with the Italian Data Protection Act and related data protection laws. For more information on the Italian Data Protection Act and your related rights please see the Information Commissioner’s Office website www.garanteprivacy.it/home_en/italian-legislation.
Children & young people
Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 13. If you are under the age of 13, we request that you do not provide us with your information and do not use our websites and apps. If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. In addition to “your choices” outlined in this Policy, we will delete or otherwise cease processing your child’s personal information within a reasonable time. If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps.
Email & SMS marketing
You can opt out of a particular marketing campaign or newsletter subscription by clicking on the ‘unsubscribe’ link in each email. You can opt out of marketing text messages by replying ‘STOP’. In accordance with industry best practice guidelines, we may retain your information (including your election to opt out) for a reasonable amount of time to make sure that we do not contact you in the future.
Use of your location
You can choose whether to provide us with your precise location from your device through your browser’s “Help” menu, or through the “Location” or “Location Services” options in the “Settings” section on your mobile device.
Use of push notifications
You will be prompted to choose whether to receive push notifications the first time you run each of our apps, and you can update your preferences at any time through Settings on your device.
What are cookies and how do they work?
Cookies are small files that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you. This allows websites to tailor what you see on the screen.
Do you use other technologies which are similar to cookies?
Cookies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups:
(i) Cookies that are needed to provide the service you have asked for
Some cookies are essential so you can move around our websites and use their features. Without these cookies, services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering your browsing history. For example:
- Keeping you logged in during your visit; without cookies you might have to log in on every page you go to
- When you add something to the online shopping basket, cookies make sure it’s still there when you get to the checkout
(ii) Cookies used to improve your browsing experience
These cookies allow our websites to remember choices you make, such as your language or region and they provide improved features. For example:
- Remembering your preferences and settings, including marketing preferences
- Remembering whether you’ve filled in a survey, so you’re not asked to do it again
- Showing you information that’s relevant to our products that you have
- Showing ‘related content’ links that are relevant to the page you’re looking at
- Remembering a location you’ve provided us with to provide tailored content
- Linking your browsing history collected by analytics cookies to your registration details to provide you with recommended content and marketing
- Restricting the number of times you’re shown a particular advertisement. This is sometimes called ‘frequency capping’
Cookies are also used to enable social media components on our websites, including embedded content from social media sites such as Facebook or Twitter, share buttons and videos. The cookies are set by the relevant social media provider. For more information about these cookies, including how to set your preferences for these cookies, please refer to the relevant social media provider’s website for more information.
(iii) Cookies used to understand how people use our products and services (Analytics)
(iv) Cookies used to show advertising that is relevant to you
Your cookie choices
Your ad choices
When using a mobile device, you can opt out of receiving online behavioural advertising by selecting ‘Limit Ad Tracking’ in the Settings of your Apple iPhone or iPad, or the “Opt out of interest-based ads” in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioural advertising (referred to as an “Advertising ID”) in the Settings on your Apple or Android device. You may change your social media advertising preferences within the social media site. For instance, on Facebook you can select “Hide all from this advertiser” to stop seeing ads from a particular advertiser.
Contacting us and accessing your personal information
If you have any queries or comments about this Privacy & Cookies Policy please contact us at email@example.com. If you wish to review or receive a copy of the personal information we hold about you, or further information about how we handle your information, please write to us at:
FCE GROUP srl
viale Sabotino 4
20135 Milano, Italy
Where permitted by law, we may charge a small administration fee (not exceeding the maximum permitted) in relation to fulfilling a request for access to personal information.
Changes to this Privacy & Cookies Policy
We reserve the right to make changes to our Privacy & Cookies Policy at any time. Where changes are made, we will post the revised Policy here with an updated effective date. Your continued use of our websites, apps, or other products or services will signify your acceptance of these changes.