www.kissconfidential.com (“the website”) collects some Personal Data from its Users. This document can be printed for reference by using the print command in the settings of any browser. The website has been developed and produced by Nicola Sandrey which is the legal property of KISS CONFIDENTIAL registered as of November 2023 as a business – it works in correlation with AIR.com.cy / Digital Creative Boutique Agency, which is the legal property of Nicola Sandrey, a registered limited company and has copyright protection as of 2019.  

Owner and Data Controller Owner contact email: Nicola@kissconfidential.com

Types of Data collected. Among the types of Personal Data that this Website collects, by itself or through third parties, there are Cookies; Usage Data. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed before the Data collection. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published, or shared
through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data. Methods of processing:  The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers,
hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis for processing The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law. Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof processing is necessary for compliance with a legal obligation to which the Owner is subject. Processing is related to a task that is carried out in the public interest or the exercise of official authority vested in the Owner/ processing is necessary for the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and, whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter a contract.

Place: The Data is processed at the Owner’s operating offices and in any other places where the/parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquiring with the Owner using the information provided in the contact section.

Retention time. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore: Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Personal Data collected for the Owner’s legitimate interests shall be retained if needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing if such consent is not withdrawn. Furthermore, the Owner may be obliged to/retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

The purposes of processing The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimization and distribution, Displaying content from external platforms and Analytics. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data collected for the following purposes and using the following services:  Analytics: The services in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour. 

Google Analytics (Google Ireland Limited) Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, prepare reports on its activities, and share them with other Google services.  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy – opt.  Privacy Shield participant. Displaying content from external platforms.  This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. Font Awesome (Fonticons, Inc.) Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data collected: Usage Data. Place of processing: United States – Privacy Policy. Google Fonts (Google Ireland Limited) Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy. Privacy Shield participant. Traffic optimization and distribution This type of service allows this Website to distribute its content using servers across different countries and optimize its performance.  Personal Data are processed depending on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User’s browser. Considering the widespread distribution of this system, it isn’t easy to determine the locations to which the contents that may contain the Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.) Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User’s browser, while also allowing analytical data from this Website to be collected.

Personal Data collected: Cookies; various types of Data as specified in the privacy policy of the service.  Place of processing: United States – Privacy Policy.

The Rights of Users: Users may exercise certain rights regarding their Data processed by the Owner.  Users have the right to do the following:  Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.  Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Have their Personal Data been deleted or otherwise removed? Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract of which the User is part or on pre-contractual obligations thereof.  To complain. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing: Where Personal Data is processed for the public interest, in the exercise of an official authority vested in the Owner or for the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights: Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible always within one month.

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