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Sabirvodka.com by VELYBE DI ALFONSA CIRRINCIONE with registered office in Venice (VE), via Giudecca n. 4, CAP 30142 fraction of Burano c/o studio dott. Luca Vio.

Alfonsa Cirrincione – email: amministrazione.velybe@gmail.com
Data Controller email address: amministrazione.velybe@gmail.com

Among the types of Personal Data that sabirvodka.com collects, by itself or through third parties, there are: email address; Tracker; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service; first name; last name; geographic position; gender; phone number; address; password; VAT Number; country; city; various types of Data; username; payment information; purchase history; billing address; device information; shipping address.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific information texts displayed before the Data are collected.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using Sabirvodka.com.
Unless otherwise specified, all Data requested by Sabirvodka.com is mandatory. If the User refuses to communicate them, it may be impossible for Sabirvodka.com to provide the Service. In cases where Sabirvodka.com indicates some Data as optional, Users are free not to communicate such Data, without this having any consequences on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by Sabirvodka.com or by the owners of third-party services used by Sabirvodka.com is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through Sabirvodka.com.

Methods of processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of Sabirvodka.com (administrative, commercial, marketing, legal, system administration personnel) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors may always be requested from the Data Controller.

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section containing details on the processing of Personal Data.

Se non diversamente indicato in questo documento, i Dati Personali sono trattati e conservati per il tempo richiesto dalla finalità per la quale sono stati raccolti e potrebbero essere conservati per un periodo più lungo a causa di eventuali obbligazioni legali o sulla base del consenso degli Utenti.

The user’s data is collected to allow the owner to provide the service, comply with legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of users or third parties), identify any malicious or fraudulent activity, as well as for the following purposes: contacting the user, remarketing and behavioral targeting, advertising, registration and authentication, viewing content from external platforms, access to accounts on third-party services, tag management, content and functionality performance testing (a/b testing), heat mapping and session recording, infrastructure monitoring, content commenting, statistics, interaction with live chat platforms, management of data collection and online surveys, management of support and contact requests, management of productivity-related activities, platform and hosting services, collection of privacy preferences, registration and authentication provided directly by sabirvodka.com, transfer of data outside the EU, hosting and backend infrastructure, payment management and interaction with data collection platforms and other third parties. To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data”.

Sabirvodka.com may request some Facebook permissions that allow it to perform actions with the User’s Facebook account and to collect information, including Personal Data, from it. This service allows Sabirvodka.com to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information on the following permissions, refer to the Facebook permissions documentation and the Facebook privacy policy.
The permissions requested are the following:

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and localization language and, in some cases, the Facebook “Friends”. If the User has made additional Data publicly available, the same will be available.

Access to private data
Allows access to the User’s and friends’ private data.

Allows the application to retrieve actions published by another application, as specified by the ‘app namespace’.

Birthday
Provides access to the birthday.

Email
Provides access to the User’s primary email address.

A Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows tracking Users, for example by collecting or storing information on the User’s device.

About Me
Provides access to the ‘About Me’ section of the profile.

Personal Data is collected for the following purposes and using the following services:
Access to accounts on third-party services
Commenting on contents
Contacting the User
Managing payments
Managing tags
Managing data collection and online surveys
Managing productivity-related activities
Managing support and contact requests
Heat mapping and session recording
Hosting and backend infrastructure
Interaction with live chat platforms
Interaction with data collection platforms and other third parties
Monitoring the infrastructure
Advertising
Collection of privacy preferences
Registration and authentication
Registration and authentication provided directly by Sabirvodka.com
Remarketing and behavioral targeting
Platform and hosting services
Statistics
Content and functionality performance tests (A/B testing)
Displaying content from external platforms

In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to opt out of interest-based advertising in the relevant section of the Cookie Policy.

Analysis of User Data and predictions (“profiling”)
Automated decision-making processes
Push notifications
Sale of goods and services online
Sabirvodka.com uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Legal basis of processing
The Data Controller processes Personal Data relating to the User if one of the following conditions applies:
● the User has given consent for one or more specific purposes.
● processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures;
● processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
● processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
● processing is necessary for the pursuit of the legitimate interests pursued by the Data Controller or by third parties.
In any case, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing and in particular to specify whether the processing is based on the law, provided for by a contract, or necessary to enter into a contract.

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or on the basis of the consent of the Users.
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 purposes related to the legitimate interest of the Owner shall be retained until such interest is fulfilled. The User may obtain further information regarding the legitimate interest pursued by the Owner within the relevant sections of this document or by contacting the Owner.
Where the processing is based on the User’s consent, the Owner may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Owner may be required to retain Personal Data for a longer period to comply with a legal obligation or an order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, at the end of such period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.

Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, within the limits established by law, the User has the right to:
● withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.
● object to the processing of their Data. The User may object to the processing of their Data when it occurs by virtue of a legal basis other than consent.
● access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
● verify and request rectification. The User may verify the accuracy of their Data and request its updating or correction.
● obtain the limitation of processing. The User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its conservation.
● obtain the deletion or removal of their Personal Data. The User may request the deletion of their Data by the Owner.
● receive their Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain the transfer without hindrance to another owner.
● lodge a complaint. The User can lodge a complaint with the competent data protection supervisory authority or take legal action.
Users have the right to obtain information regarding the legal basis for the transfer of Data abroad including to any international organization governed by international law or set up by two or more countries, such as the UN, as well as regarding the security measures adopted by the Owner to protect their Data.

When Personal Data is processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.
Users are informed that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge and without providing any justification. If Users object to the processing for direct marketing purposes, the Personal Data is no longer processed for such purposes. To find out whether the Owner processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

Any requests to exercise your rights may be addressed to the Owner through the contact details provided in this document. The request is free of charge and the Owner will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any corrections, cancellations or limitations of the processing will be communicated by the Owner to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Owner will inform the User of these recipients if he/she requests it.

When this is the legal basis, the transfer of Personal Data from the EU to third countries occurs on the basis of standard clauses for the protection of Personal Data adopted by the European Commission.
In such cases, the recipients of the Data have agreed to process the Personal Data in accordance with the levels of protection provided by EU legislation. Users may request further information by contacting the Data Controller at the contact details indicated in this document.

This section applies to Users in Switzerland and, for such Users, replaces any other information that may be divergent or conflicting in the privacy policy.
Further details regarding the categories of Data processed, the purposes of the processing, the categories of recipients of the personal data, if any, the retention period and other information on Personal Data can be found in the section entitled “Detailed information on the processing of Personal Data” within this document.

Users may exercise certain rights regarding their data within the limits of the law, including the following:
● right to access Personal Data;
● the right to object to the processing of their Personal Data (which also allows Users to request the limitation of the processing of Personal Data, the erasure or destruction of Personal Data, the prohibition of disclosure of Personal Data to third parties);
● right to receive their Personal Data and to transfer it to another data controller (data portability);
● right to request the rectification of incorrect Personal Data.

Any requests to exercise the User’s rights can be addressed to the Owner through the contact details provided in this document. These requests are free of charge and the Owner will respond as soon as possible, providing Users with the information required by law.