Tuame.com collects some Personal Data from its Users.
Owner and Data Controller
Viale Marconi, 55
64016 Sant'Egidio alla Vibrata
VAT number: 01044990677
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that Tuame.com collects, by itself or through third parties, there are: first name; last name; username; email address; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Tuame.com.
Unless specified otherwise, all Data requested by Tuame.com is mandatory and failure to provide this Data may make it impossible for Tuame.com to provide its services. In cases where Tuame.com 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.
Users are responsible for any third-party Personal Data obtained, published or shared through Tuame.com 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.
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 the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Tuame.com (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 of 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 in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of 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 in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
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 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 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 inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- 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 purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill 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, as long as 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 expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Registration and authentication, Analytics, Contacting the User, Managing contacts and sending messages 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:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics with anonymized IP (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 Tuame.com, 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.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data collected: Cookies; Usage Data.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Tuame.com. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data collected: Cookies; Usage Data.
Google Analytics for Firebase (Google Inc.)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Inc.
In order to understand Google's use of Data, consult Google's partner policy.
Tuame.com uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Personal Data collected: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
- Contacting the User
Mailing list or newsletter (Tuame.com)
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 Tuame.com. Your email address might also be added to this list as a result of signing up to Tuame.com or after making a purchase.
Personal Data collected: email address.
- 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.
MailUp is an email address management and message sending service provided by MailUp SpA.
Personal Data collected: email address.
- Registration and authentication
By registering or authenticating, Users allow Tuame.com 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, Tuame.com will be able to access some Data, stored by these third party services, for registration or identification purposes.
Direct registration (Tuame.com)
The User registers by filling out the registration form and providing the Personal Data directly to Tuame.com
Personal Data collected: email address; first name; last name; username.
- Remarketing and behavioral targeting
This type of service allows Tuame.com and its partners to inform, optimize and serve advertising based on past use of Tuame.com 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.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of Tuame.com with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies; Usage Data.
Further information about Personal Data
- Direct Email Marketing (DEM) (Tuame.com)
Tuame.com uses the User's Data to submit commercial proposals for services and products provided by third parties or not related to the product or service provided by Tuame.com.
In particular, if the User consents to such processing, the Data Controller may send promotional messages by e-mail regarding its services and, if the User is a Professional, regarding products, services, articles or medical and pharmaceutical equipment, in all other cases, relating to the services offered by the Professionals registered on the portal.
Personal Data collected: email.
If the User consents to such treatment, the Owner may save and use the Personal Data collected on the basis of this document, particularly if associated with the areas of interest selected during the registration process, to create User profiles in order to send commercial and / or promotional messages in line with previously expressed preferences, including those expressed in the course of their browsing activities on Tuame.com. The User will always have the right to withdraw his or her consent to the profiling activity, by simply sending an email to the contact information contained in this document.
- Use under a pseudonym
When registering on Tuame.com, the User has the option of specifying a pseudonym or nickname that will be displayed in connection with the materials (texts, photos, information etc.) published by the User on Tuame.com. In this case, the User's personal data will not be made public in connection with such materials. However, the User acknowledges and accepts that the content of the materials may, depending on the circumstances, allow the identity of the User to be back-traced. It is therefore advisable to avoid describing personal situations that allow one's own identification.
- Sensitive data
For the operation of Tuame.com, the User is not required to communicate data revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, trade unions, associations or organizations of a religious, philosophical, political or trade-union nature, as well as personal data revealing health and sex life (i. e. sensitive data).
However, the User acknowledges and accepts that, by contacting the Professional, they are free to indicate their needs, describe any pathologies or, in any case, transmit sensitive data or information that allows to trace sensitive data.
Tuame.com merely provides a technological infrastructure for the transmission of such data between Users and Professionals, storing communications on its servers (hosting) and therefore acting as external Data Processor.
In the meantime, Tuame.com does not collect, disseminate, publish, resell, assign to third parties nor exploit for its own purposes the data and information contained in communications between Users and Professionals.
Semrush is an analytics service provided by Semrush Inc. This service allows to analyse and assess the effectiveness of online marketing campaigns.
- Sharing of User's Personal Data with the Professional
The User understands that, with reference to personal information and data communicated by the User to the Professional (i.e., a natural or legal person who provides professional medical and cosmetic surgery services) for the purpose of establishing a first appointment, Tuame.com provides a purely technical service of simple transmission, without access to said contents, nor does it collect personal data.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
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 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 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 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 the Owner or for the purposes of the legitimate interests pursued by the Owner, 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 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 and always within one month.