DEFINITIONS AND LEGAL REFERENCES
PERSONAL DATA (OR DATA)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
USAGE DATA
Information collected automatically through this website (or third-party services employed in this website), which can include: the IP addresses or domain names of the computers utilized by the users who use this website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the website) and the details about the path followed within the website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
USER
The individual using this website who, unless otherwise specified, coincides with the data subject.
DATA SUBJECT
The natural person to whom the personal data refers.
DATA PROCESSOR
The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this privacy policy.
DATA CONTROLLER
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this website. The data controller, unless otherwise specified, is the owner of this website.
THIS WEBSITE
The means by which the personal data of the user is collected and processed.
SERVICE
The service provided by this website as described in the relative terms (if available) and on this site/application.
EUROPEAN UNION (OR EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
COOKIES
Small sets of data stored in the user’s device.
LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this website, if not stated otherwise within this document.
TYPES OF DATA COLLECTED
Among the types of personal data that this website collects, by itself or through third parties, there are: cookies, username, email address, various types of data, usage data, website, first name and last name. 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 prior to the data collection. Personal data may be freely provided by the user, or, in 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 Narana Capital. Any use of cookies – or of 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 in the cookie policy. 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
Narana Capital takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The 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 Narana Capital, in some cases, the data may be accessible to certain types of external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors. The updated list of these parties may be requested from Narana Capital at any time.
LEGAL BASIS OF PROCESSING
Narana Capital 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 Narana Capital 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 Narana Capital is subject
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Narana Capital
processing is necessary for the purposes of the legitimate interests pursued by Narana Capital or by a third party.
In any case, CodexTheme will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
PLACE
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 to 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 Narana Capital to safeguard their data. If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with Narana Capital using this contact form.
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 Narana Capital and the user shall be retained until such contract has been fully performed. Personal data collected for the purposes of the Narana Capital legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Narana Capital within the relevant sections of this document or by contacting Narana Capital. Narana Capital may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, Narana Capital 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 expiration of the retention period.
THE PURPOSES OF PROCESSING
The data concerning the user is collected to allow Narana Capital to provide its services, as well as for the following purposes: traffic optimization and distribution, hosting and backend infrastructure, registration and authentication, analytics, displaying content from external platforms, managing contacts and sending messages, contacting the user, managing support and contact requests, content commenting, SPAM protection and remarketing and behavioral targeting. Users can find further detailed information about such purposes of processing and about the specific personal data used for each purpose in the respective sections of this document.
DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal data is collected for the following purposes and using the following services:
ANALYTICS
The services contained in this section enable Narana Capital to monitor and analyze web traffic and can be used to keep track of user behavior.
GOOGLE ANALYTICS (GOOGLE INC.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this website, to 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 and usage data.
Place of processing: US – Privacy Policy – Opt Out.
CONTACTING THE USER
MAILING LIST OR NEWSLETTER (THIS WEBSITE)
By registering on the mailing list or for the newsletter, the user’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this website. Your email address might also be added to this list as a result of signing up to this website, signing up to Narana Capital support center or after making a purchase.
Personal Data collected: email address.
CONTACT FORM (THIS WEBSITE)
By filling in the contact form with their data, the user authorizes this website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
CONTENT COMMENTING
Content commenting services allow users to make and publish their comments on the contents of this website. Depending on the settings chosen by Narana Capital, users may also leave anonymous comments. If there is an email address among the personal data provided by the user, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when users do not use the content commenting service.
COMMENT SYSTEM MANAGED DIRECTLY (THIS WEBSITE)
This Application has its own internal content comment system.
Personal Data collected: email address, username and website.
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.
GOOGLE FONTS (GOOGLE INC.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this website to incorporate content of this kind on its pages.
Personal Data collected: usage data and various types of data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
GOOGLE MAPS WIDGET (GOOGLE INC.)
Google Maps is a maps visualization service provided by Google Inc. that allows this website to incorporate content of this kind on its pages.
Personal Data collected: Cookies and usage data.
Place of processing: US – Privacy Policy.
GRAVATAR (AUTOMATTIC INC.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this website to incorporate content of this kind on its pages. Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data collected: email address and usage data.
Place of processing: US – Privacy Policy.
INSTAGRAM WIDGET (INSTAGRAM, INC.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this website to incorporate content of this kind on its pages.
Personal Data collected: Cookies and usage data.
Place of processing: US – Privacy Policy.
VIMEO VIDEO (VIMEO, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this website to incorporate content of this kind on its pages.
Personal Data collected: Cookies and usage data.
Place of processing: US – Privacy Policy.
YOUTUBE VIDEO WIDGET (GOOGLE INC.)
YouTube is a video content visualization service provided by Google Inc. that allows this website to incorporate content of this kind on its pages.
Personal Data collected: Cookies and usage data.
Place of processing: US – Privacy Policy.
HOSTING AND BACKEND INFRASTRUCTURE
This type of service has the purpose of hosting data and files that enable this website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data are stored.
DIGITALOCEAN (DIGITALOCEAN INC.)
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Personal Data collected: various types of data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
OVH
OVH is a hosting service provided by OVH Canada.
Personal Data collected: various types of data as specified in the privacy policy of the service.
Place of processing: Canada – Privacy Policy.
MANAGING CONTACTS AND SENDING MESSAGES
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the user.
These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.
MAILCHIMP (THE ROCKET SCIENCE GROUP, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: email address.
Place of processing: US – Privacy Policy.
MANAGING SUPPORT AND CONTACT REQUESTS
This type of service allows this website to manage support and contact requests received via email or by other means, such as the contact form. The personal data processed depend on the information provided by the user in the messages and the means used for communication (e.g. email address).
TICKSY
Ticksy is a support and contact request management service provided by Ticksy Limited.
Personal Data collected: various types of data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy.
REGISTRATION AND AUTHENTICATION
By registering or authenticating, users allow this website to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this website will be able to access some data, stored by these third-party services, for registration or identification purposes.
DIRECT REGISTRATION (THIS WEBSITE)
The user registers by filling out the registration form and providing the personal data directly to this website.
Personal Data collected: email address, username and various types of data.
REMARKETING AND BEHAVIORAL TARGETING
This type of service allows this website and its partners to inform, optimize and serve advertising based on past use of this website by the user.
This activity is performed by tracking usage data and by using cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the user may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
GOOGLE ADWORDS REMARKETING (GOOGLE INC.)
Google AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this website with the Google advertising network.
Personal Data collected: Cookies and usage data.
Place of processing: United States – Privacy Policy – Opt Out.
TRAFFIC OPTIMIZATION AND DISTRIBUTION
This type of service allows this website to distribute their content using servers located across different countries and to optimize their performance. Which personal data are processed depends 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 is difficult to determine the locations to which the contents that may contain personal information user are transferred.
MAXCDN (NETDNA, LLC)
MaxCDN is a traffic optimization and distribution service provided by NetDNA, LLC
The way MaxCDN 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 and various types of data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
THE RIGHTS OF USERS
Users may exercise certain rights regarding their data processed by Narana Capital.
In particular, 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 Narana Capital, 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, Narana Capital will not process their Data for any purpose other than storing it.
HAVE THEIR PERSONAL DATA DELETED OR OTHERWISE REMOVED
Users have the right, under certain circumstances, to obtain the erasure of their data from Narana Capital.
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 which the user is part of or on pre-contractual obligations thereof.
LODGE A COMPLAINT
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 a public interest, in the exercise of an official authority vested in Narana Capital or for the purposes of the legitimate interests pursued by Narana Capital, users may object to such processing by providing a ground related to their particular 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 Narana Capital 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 Narana Capital through the contact form. These requests can be exercised free of charge and will be addressed by Narana Capital as early as possible and always within one month.
COOKIE POLICY
This website uses cookies. To learn more and for a detailed cookie notice, the user may consult the cookie policy.
ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
LEGAL ACTION
The user’s personal data may be used for legal purposes by Narana Capital in Court or in the stages leading to possible legal action arising from improper use of this website or the related Services. The user declares to be aware that Narana Capital may be required to reveal personal data upon request of public authorities.
ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA
In addition to the information contained in this privacy policy, this website may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.
SYSTEM LOGS AND MAINTENANCE
For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (system logs) use other personal data (such as the IP address) for this purpose.
INFORMATION NOT CONTAINED IN THIS POLICY
More details concerning the collection or processing of personal data may be requested from Narana Capital at any time. Please see the contact information at the beginning of this document.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
This website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CHANGES TO THIS PRIVACY POLICY
Narana Capital reserves the right to make changes to this privacy policy at any time by giving notice to its users on this page and possibly within this website and/or – as far as technically and legally feasible – sending a notice to users via any contact information available to Narana Capital. It is strongly recommended to check this page often. If a user objects to any of the changes to the policy, the user must cease using this website and can request that Narana Capital removes the personal data. Unless stated otherwise, the then-current privacy policy applies to all personal data Narana Capital has about user
