Last
updated
October 20, 2022
This privacy notice
for
Sorrentino.pro
(
‘
Company
‘, ‘we‘, ‘us‘, or
‘our‘,
), describes how and why we might collect, store, use, and/or
share (
‘process‘
)
your information when you use our services (
‘Services‘
), such as when
you:
-
Visit our
website
at https://sorrentino.pro , or any website of ours that links to this privacy notice
-
Download and
use
our mobile application ( Sorrentinopro) , or any other application of ours that links to this privacy notice
-
Engage with us
in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy
notice will help you understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services. If you still have any questions or concerns,
please contact us at
francesco@sorrentino.pro
.
SUMMARY OF
KEY POINTS
This
summary provides key points from our privacy notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using our table of contents
below to find the section you are looking for. You can also
click here to go directly to our table
of contents.
What
personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with
Sorrentino.pro
and the Services, the choices you make, and the products
and features you use. Click
here to learn more.
Do we
process any sensitive personal information?
We may process sensitive personal information when necessary with
your consent or as otherwise permitted by applicable law. Click
here
to learn more.
Do we
receive any information from third parties?
We may receive information from public databases, marketing partners,
social media platforms, and other outside sources. Click
here
to learn more.
How do we
process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent. We process your information only
when we have a valid legal reason to do so. Click here to learn more.
In what
situations and with which
parties do we share personal
information?
We may share information in specific situations and with specific
third parties. Click
here
to learn more.
How do we
keep your information safe? We have
organisational
and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other
unauthorised
third parties will
not be able to defeat our security and improperly collect, access, steal, or modify your information.
Click
here
to learn more.
What are
your rights? Depending on where you are located geographically, the applicable privacy law
may mean you have certain rights regarding your personal information. Click here to learn more.
How do you
exercise your rights? The easiest way to exercise your rights is by filling out our data
subject request form available
here
, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more
about what
Sorrentino.pro
does with any information we collect? Click
here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION
DO WE COLLECT?
Personal information you disclose to
us
In
Short:
We collect
personal information that you provide to
us.
We collect personal
information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal
Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:
-
names
-
email addresses
-
usernames
-
debit/credit card numbers
-
billing addresses
-
contact or authentication data
-
contact preferences
-
passwords
-
job titles
-
mailing addresses
-
phone numbers
Sensitive Information.
When necessary, with your consent or as otherwise permitted by
applicable law, we process the following categories of sensitive information:
-
social security numbers or other government identifiers
-
student data
-
credit worthiness data
-
information revealing trade union membership
-
information revealing religious or philosophical beliefs
-
information revealing political opinions
-
information revealing race or ethnic origin
-
data about a person’s sex life or sexual orientation
-
biometric data
-
genetic data
-
financial data
-
health data
Payment
Data. We may collect data necessary to process your payment if you make purchases, such
as your payment instrument number, and the security code associated with your payment instrument.
All payment data is stored by
Paypal
.
You may find their privacy notice link(s) here:
https://www.paypal.com/privacy-center
.
Social
Media Login Data. We may provide you with the option to register with us using
your existing social media account details, like your Facebook, Twitter, or other social media
account. If you choose to register in this way, we will collect the information described in the
section called
‘
HOW DO WE HANDLE YOUR
SOCIAL
LOGINS?
‘
below.
Application
Data. If you use our application(s), we also may
collect the following information if you choose to provide us with access or permission:
-
Geolocation
Information. We may request access or permission to track location-based information from
your mobile device, either continuously or while you are using our mobile application(s), to provide
certain location-based services. If you wish to change our access or permissions, you may do so in
your device’s settings.
-
Mobile
Device Access. We may request access or permission to certain features from your mobile
device, including your mobile device’s
bluetooth ,calendar ,camera ,contacts ,microphone ,reminders ,sensors ,sms messages ,social media accounts ,storage ,and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
-
Mobile
Device Data. We automatically collect device information (such as your mobile device ID,
model, and manufacturer), operating system, version information and system configuration
information, device and application identification numbers, browser type and version, hardware model
Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy
server). If you are using our application(s), we may also collect information about the phone
network associated with your mobile device, your mobile device’s operating system or platform, the
type of mobile device you use, your mobile device’s unique device ID, and information about the
features of our application(s) you accessed.
-
Push
Notifications. We may request to send you push notifications regarding your account or
certain features of the application(s). If you wish to opt out from receiving these types of
communications, you may turn them off in your device’s settings.
This information
is primarily needed to maintain the security and operation of our application(s), for troubleshooting,
and for our internal analytics and reporting purposes.
All personal
information that you provide to us must be true, complete, and accurate, and you must notify us of
any changes to such personal information.
Information automatically collected
In
Short: Some information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our
Services.
We automatically
collect certain information when you visit, use, or navigate the Services. This information does not
reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and reporting
purposes.
Like many
businesses, we also collect information through cookies and similar technologies.
The information we
collect includes:
-
Log and
Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we
record in log files. Depending on how you interact with us, this log data may include your IP
address, device information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches, and other actions you take such as which
features you use), device event information (such as system activity, error reports (sometimes
called
‘crash dumps’ ), and hardware settings).
-
Device
Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. Depending on the device used, this device data may
include information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service provider and/or
mobile carrier, operating system, and system configuration information.
-
Location
Data. We collect location data such as information about your device’s location, which
can be either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by refusing access
to the information or by disabling your Location setting on your device. However, if you choose
to opt out, you may not be able to use certain aspects of the Services.
Information collected from other
sources
In
Short:
We may
collect limited data from public databases, marketing partners,
social media platforms,
and other outside
sources.
In order to enhance
our ability to provide relevant marketing, offers, and services to you and update our records, we
may obtain information about you from other sources, such as public databases, joint marketing
partners, affiliate programs, data providers,
social media platforms,
and from other third parties. This information includes mailing
addresses, job titles, email addresses, phone numbers, intent data (or user
behaviour
data), Internet Protocol
(IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of
targeted advertising and event promotion.
If you interact with us on a social media platform
using your social media account (e.g.
Facebook or
Twitter), we receive personal information about you such as your name, email address,
and gender. Any personal information that we collect from your social media account
depends on your social media account’s privacy
settings.
2. HOW DO WE
PROCESS YOUR INFORMATION?
In
Short: We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your
consent.
We process
your personal information for a variety of reasons, depending on how you interact with our
Services, including:
-
To
facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
-
To
deliver and facilitate delivery of services to the user. We may process
your information to provide you with the requested service.
-
To respond to user
inquiries/offer support to
users. We may process your information to respond to your inquiries
and solve any potential issues you might have with the requested service.
-
To send
administrative information to
you. We may process your information to send you details about our
products and services, changes to our terms and policies, and other similar
information.
-
To
fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
-
To enable user-to-user
communications. We may process your information if you
choose to use any of our offerings that allow for communication with another
user.
-
To request feedback. We
may process your information when necessary to request feedback and to
contact you about your use of our Services.
-
To
send you marketing and promotional
communications. We may process the personal information
you send to us for our marketing purposes, if this is in accordance with
your marketing preferences. You can opt out of our marketing emails at any
time. For more information, see
‘ WHAT ARE YOUR PRIVACY RIGHTS? ‘ below).
-
To deliver targeted advertising to
you. We may process your information to develop and display
personalised
-
To protect our Services.
We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and
prevention.
-
To identify usage
trends. We may process information about
how you use our Services to better understand how they
are being used so we can improve them.
-
To determine
the effectiveness of our marketing and
promotional campaigns. We may process
your information to better understand how to provide
marketing and promotional campaigns that are most
relevant to you.
-
To save or
protect an individual’s vital
interest. We may process your
information when necessary to save or protect an
individual’s vital interest, such as to prevent
harm.
3.
WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We only process your
personal information when we believe it is
necessary and we have a valid legal reason (i.e.
legal basis)
to do so under applicable law, like with your
consent, to comply with laws, to provide you
with services to enter into or
fulfil
our contractual
obligations, to protect your rights, or to
fulfil
our legitimate
business interests.
If you
are located in the EU or UK, this
section applies to
you.
The
General Data
Protection Regulation (GDPR) and UK GDPR require us
to explain the valid legal bases we rely on in order
to process your personal information. As such, we
may rely on the following legal bases to process
your personal information:
-
Consent. We
may process your information if you have given
us permission (i.e.
-
Performance of
a Contract. We may process your
personal information when we believe it is
necessary to
fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
-
Send users information
about special offers and discounts on our
products and services
-
Develop and display
personalised and relevant advertising content for our users
-
Analyse how our Services are used so we can improve them to engage and retain users
-
Support our marketing
activities
-
Diagnose problems
and/or prevent fraudulent activities
-
Understand how our
users use our products and services so we can
improve user experience
-
Legal
Obligations. We may process your
information where we believe it is necessary for
compliance with our legal obligations, such as
to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence
in litigation in which we are involved.
-
Vital
Interests. We may process your
information where we believe it is necessary to
protect your vital interests or the vital
interests of a third party, such as situations
involving potential threats to the safety of any
person.
If you are
located in Canada, this section applies
to you.
We may process your
information if you have given us specific permission
(i.e.
express
consent) to use your personal information for a
specific purpose, or in situations where your
permission can be inferred (i.e.
implied consent).
You can withdraw your consent at any time.
Click
here to learn
more.
In some exceptional cases,
we may be legally permitted under applicable law to
process your information without your consent,
including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For investigations and
fraud detection and prevention
-
For business
transactions provided certain conditions are
met
-
If it is contained in a
witness statement and the collection is
necessary to assess, process, or settle an
insurance claim
-
For identifying
injured, ill, or deceased persons and
communicating with next of kin
-
If we have reasonable
grounds to believe an individual has been, is,
or may be victim of financial abuse
-
If it is reasonable to
expect collection and use with consent would
compromise the availability or the accuracy of
the information and the collection is reasonable
for purposes related to investigating a breach
of an agreement or a contravention of the laws
of Canada or a province
-
If disclosure is
required to comply with a subpoena, warrant,
court order, or rules of the court relating to
the production of records
-
If
it was produced
by an individual in the course of their
employment, business, or profession and the
collection is consistent with the purposes for
which the information was produced
-
If
the collection
is solely for journalistic, artistic, or
literary purposes
-
If
the information
is publicly available and is specified by the
regulations
In
Short:
We may
share information in specific situations
described in this section and/or with the
following
third
parties.
We
may need to share
your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
-
When we
use Google Maps Platform APIs. We
may share your information with certain Google
Maps Platform APIs (e.g.
Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link . We obtain and store on your device ( ‘cache’ ) your location . You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
-
Affiliates. We
may share your information with our affiliates,
in which case we will require those affiliates
to
honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
-
Business
Partners. We may share your
information with our business partners to offer
you certain products, services, or
promotions.
-
Other
Users. When you share personal
information
or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
-
Offer
Wall. Our application(s) may
display a third-party hosted
‘offer wall’. Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
5.
WHAT IS OUR
STANCE ON THIRD-PARTY
WEBSITES?
In
Short: We are not
responsible for the safety of any information
that you share with third parties that we may
link to or who advertise on our Services, but
are not affiliated with, our
Services.
The
Services
, including our
offer wall,
may
link to third-party websites, online services, or
mobile applications and/or contain advertisements
from third parties that are not affiliated with us
and which may link to other websites, services, or
applications. Accordingly, we do not make any
guarantee regarding any such third parties, and we
will not be liable for any loss or damage caused by
the use of such third-party websites, services, or
applications. The inclusion of a link towards a
third-party website, service, or application does
not imply an endorsement by us. We cannot guarantee
the safety and privacy of data you provide to any
third parties. Any data collected by third parties
is not covered by this privacy notice. We are not
responsible for the content or privacy and security
practices and policies of any third parties,
including other websites, services, or applications
that may be linked to or from the Services. You
should review the policies of such third parties and
contact them directly to respond to your questions.
In
Short: We may use
cookies and other tracking technologies to
collect and store your
information.
We may use cookies
and similar tracking technologies (like web
beacons and pixels) to access or store
information. Specific information about how we
use such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.
In
Short: If you
choose to register or log in to our Services
using a social media account, we may have
access to certain information about
you.
Our Services offer
you the ability to register and log in using
your third-party social media account details
(like your Facebook or Twitter logins). Where
you choose to do this, we will receive certain
profile information about you from your social
media provider. The profile information we
receive may vary depending on the social media
provider concerned, but will often include your
name, email address, friends list, and profile
picture, as well as other information you choose
to make public on such a social media platform.
We will use the
information we receive only for the purposes
that are described in this privacy notice or
that are otherwise made clear to you on the
relevant Services. Please note that we do not
control, and are not responsible for, other uses
of your personal information by your third-party
social media provider. We recommend that you
review their privacy notice to understand how
they collect, use, and share your personal
information, and how you can set your privacy
preferences on their sites and apps.
8.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short:
We keep
your information for as long as necessary to
fulfil
the purposes
outlined in this privacy notice unless
otherwise required by
law.
We will only keep
your personal information for as long as it is
necessary for the purposes set out in this
privacy notice, unless a longer retention period
is required or permitted by law (such as tax,
accounting, or other legal requirements).
No purpose in
this notice will require us keeping your
personal information for longer than
twelve (12)
months
past the termination of the user’s account
.
When we have no
ongoing legitimate business need to process your
personal information, we will either delete or
anonymise
such information,
or, if this is not possible (for example,
because your personal information has been
stored in backup archives), then we will
securely store your personal information and
isolate it from any further processing until
deletion is possible.
9.
HOW DO WE KEEP YOUR INFORMATION
SAFE?
In
Short:
We aim to
protect your personal information through a
system of
organisational
and technical security
measures.
We have
implemented appropriate and reasonable technical
and
organisational
security measures designed to protect the
security of any personal information we process.
However, despite our safeguards and efforts to
secure your information, no electronic
transmission over the Internet or information
storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other
unauthorised
third parties
will not be able to defeat our security and
improperly collect, access, steal, or modify
your information. Although we will do our best
to protect your personal information,
transmission of personal information to and from
our Services is at your own risk. You should
only access the Services within a secure
environment.
10.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In
some regions, such as
the
European Economic Area (EEA), United Kingdom
(UK), and Canada
, you have
rights that allow you greater access to and
control over your personal information.
You
may review, change, or terminate your
account at any time.
In some regions
(like
the
EEA, UK, and Canada
), you have certain rights under
applicable data protection laws. These may
include the right (i) to request access and
obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to
restrict the processing of your personal
information; and (iv) if applicable, to data
portability. In certain circumstances, you may
also have the right to object to the processing
of your personal information. You can make such
a request by contacting us by using the contact
details provided in the section
‘
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
‘
below.
We will consider
and act upon any request in accordance with
applicable data protection laws.
If you are located
in the EEA or UK and you believe we are
unlawfully processing your personal information,
you also have the right to complain to your
local data protection supervisory authority. You
can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located
in Switzerland, the contact details for the data
protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your consent: If we are
relying on your consent to process your personal
information,
which may be express and/or implied consent
depending on the applicable law,
you have the right to withdraw your consent at
any time. You can withdraw your consent at any
time by contacting us by using the contact
details provided in the section
‘
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
‘
below
.
However, please note
that this will not affect the lawfulness of the
processing before its withdrawal nor,
when applicable
law allows,
will it affect the processing of your
personal information conducted in reliance on lawful
processing grounds other than consent.
Opting out
of marketing and promotional
communications: You
can unsubscribe from our marketing and promotional
communications at any time by
clicking on the
unsubscribe link in the emails that we send,
or by contacting
us using the details provided in the section
‘
HOW
CAN YOU
CONTACT US ABOUT THIS
NOTICE?
‘
below. You will then
be removed from the marketing lists. However, we may
still communicate with you — for example, to send
you service-related messages that are necessary for
the administration and use of your account, to
respond to service requests, or for other
non-marketing purposes.
Account
Information
If you would at any time
like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon
your request to
terminate your account, we will deactivate or delete
your account and information from our active
databases. However, we may retain some information
in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce
our legal terms and/or comply with applicable legal
requirements.
Cookies
and similar technologies:
Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose
to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies
or reject cookies, this could affect certain
features or services of our Services. To opt out
of interest-based advertising by advertisers on
our Services visit http://www.aboutads.info/choices/.
If you have questions or
comments about your privacy rights, you may email us
at
privacy@sorrentino.pro
.
11.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers
and some mobile operating systems and mobile
applications include a Do-Not-Track (
‘DNT’
) feature or
setting you can activate to signal your privacy
preference not to have data about your online
browsing activities monitored and collected. At
this stage no uniform technology standard for
recognising
and implementing
DNT signals has been
finalised
. As such, we do
not currently respond to DNT browser signals or
any other mechanism that automatically
communicates your choice not to be tracked
online. If a standard for online tracking is
adopted that we must follow in the future, we
will inform you about that practice in a revised
version of this privacy
notice.
12.
DO CALIFORNIA RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if
you are a resident of California, you are
granted specific rights regarding access to
your personal
information.
California Civil
Code Section 1798.83, also known as the
‘Shine The
Light’
law,
permits our users who are California residents
to request and obtain from us, once a year and
free of charge, information about categories of
personal information (if any) we disclosed to
third parties for direct marketing purposes and
the names and addresses of all third parties
with which we shared personal information in the
immediately preceding calendar year. If you are
a California resident and would like to make
such a request, please submit your request in
writing to us using the contact information
provided below.
If you are under
18 years of age, reside in California, and have
a registered account with Services, you have the
right to request removal of unwanted data that
you publicly post on the Services. To request
removal of such data, please contact us using
the contact information provided below and
include the email address associated with your
account and a statement that you reside in
California. We will make sure the data is not
publicly displayed on the Services, but please
be aware that the data may not be completely or
comprehensively removed from all our systems
(e.g.
backups, etc.).
CCPA Privacy
Notice
The
California Code of Regulations
defines a
‘resident’
as:
(1) every
individual who is in the State of California for
other than a temporary or transitory purpose
and
(2) every
individual who is domiciled in the State of
California who is outside the State of
California for a temporary or transitory
purpose
All other
individuals are defined as
‘non-residents’.
If this definition
of
‘resident’
applies to you,
we must adhere to certain rights and obligations
regarding your personal
information.
What
categories of personal information do we
collect?
We have collected
the following categories of personal information
in the past twelve (12) months:
Category | Examples | Collected |
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address, telephone
or mobile contact number, unique
personal identifier, online
identifier, Internet Protocol
address, email address, and
account
name
|
|
B.
Personal information categories
listed in the California
Customer Records
statute
|
Name,
contact information, education,
employment, employment history,
and financial
information
|
|
C.
Protected classification
characteristics under California
or federal
law
|
Gender
and date of
birth
|
|
D.
Commercial
information
|
Transaction
information, purchase history,
financial details, and payment
information
|
|
E.
Biometric
information
|
Fingerprints
and
voiceprints
|
|
F.
Internet or other similar
network
activity
|
Browsing
history, search history, online
|
|
G.
Geolocation
data
|
Device
location
|
|
H.
Audio, electronic, visual,
thermal, olfactory, or similar
information
|
Images
and audio, video or call
recordings created in connection
with our business
activities
|
|
I.
Professional or
employment-related
information
|
Business
contact details in order to
provide you our Services at a
business level or job title,
work history, and professional
qualifications if you apply for
a job with
us
|
|
J.
Education
Information
|
Student
records and directory
information
|
|
K.
Inferences drawn from other
personal
information
|
Inferences
drawn from any of the collected
personal information listed
above to create a profile or
summary about, for example, an
individual’s preferences and
characteristics
|
|
We may also
collect other personal information outside of
these categories through instances where you
interact with us in person, online, or by phone
or mail in the context of:
-
Receiving help
through our customer support
channels;
-
Participation
in customer surveys or contests;
and
-
Facilitation
in the delivery of our Services and to
respond to your inquiries.
How do we
use and share your personal
information?
You may contact us
by email at
Privacy@sorrentino.pro
,
or by referring to the
contact details at the bottom of this document.
If you are using
an
authorised
agent to exercise
your right to opt out we may deny a request if
the
authorised
agent
does not submit proof that they have been
validly
authorised
to act
on your behalf.
Will your
information be shared with anyone
else?
We may disclose
your personal information with our service
providers pursuant to a written contract between
us and each service provider. Each service
provider is a for-profit entity that processes
the information on our
behalf.
We may use your
personal information for our own business
purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be
‘selling’
of your personal
information.
Your
rights with respect to your personal
data
Right to
request deletion of the data — Request to
delete
You can ask for
the deletion of your personal information. If
you ask us to delete your personal information,
we will respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but not
limited to) the exercise by another consumer of
his or her right to free speech, our compliance
requirements resulting from a legal obligation,
or any processing that may be required to
protect against illegal
activities.
Right to be
informed — Request to
know
Depending on the
circumstances, you have a right to know:
-
whether we
collect and use your personal
information;
-
the categories
of personal information that we
collect;
-
the purposes
for which the collected personal information
is used;
-
whether we
sell your personal information to third
parties;
-
the categories
of personal information that we sold or
disclosed for a business purpose;
-
the categories
of third parties to whom the personal
information was sold or disclosed for a
business purpose; and
-
the business
or commercial purpose for collecting or
selling personal information.
In accordance with
applicable law, we are not obligated to provide
or delete consumer information that is
de-identified in response to a consumer request
or to re-identify individual data to verify a
consumer request.
Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights
We will not
discriminate against you if you exercise your
privacy rights.
Verification
process
Upon receiving
your request, we will need to verify your
identity to determine you are the same person
about whom we have the information in our
system. These verification efforts require us to
ask you to provide information so that we can
match it with information you have previously
provided us. For instance, depending on the type
of request you submit, we may ask you to provide
certain information so that we can match the
information you provide with the information we
already have on file, or we may contact you
through a communication method (e.g.
phone or
email) that you have previously provided to us.
We may also use other verification methods as
the circumstances dictate.
We will only use
personal information provided in your request to
verify your identity or authority to make the
request. To the extent possible, we will avoid
requesting additional information from you for
the purposes of verification. However, if we
cannot verify your identity from the information
already maintained by us, we may request that
you provide additional information for the
purposes of verifying your identity and for
security or fraud-prevention purposes. We will
delete such additionally provided information as
soon as we finish verifying
you.
Other privacy
rights
-
You may object
to the processing of your personal
information.
-
You may
request correction of your personal data if
it is incorrect or no longer relevant, or
ask to restrict the processing of the
information.
-
You can
designate an
authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
-
You may
request to opt out from future selling of
your personal information to third parties.
Upon receiving an opt-out request, we will
act upon the request as soon as feasibly
possible, but no later than fifteen (15)
days from the date of the request
submission.
To exercise these
rights, you can contact us
by email at
Privacy@sorrentino.pro
,
or by referring to the
contact details at the bottom of this document. If you
have a complaint about how we handle your data, we would
like to hear from you.
13.
DO WE MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we will update
this notice as necessary to stay compliant
with relevant
laws.
We may update this
privacy notice from time to time. The updated
version will be indicated by an updated
‘Revised’
date and the
updated version will be effective as soon as it
is accessible. If we make material changes to
this privacy notice, we may notify you either by
prominently posting a notice of such changes or
by directly sending you a notification. We
encourage you to review this privacy notice
frequently to be informed of how we are
protecting your
information.
14.
HOW CAN YOU CONTACT US ABOUT
THIS
NOTICE?
If you have
questions or comments about this notice, you may
email
us at
privacy@sorrentino.pro
or
by post
to:
15.
HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM
YOU?