The Data Controller is Bending Spoons S.p.A., based in Corso Como 15, Milan, MI 20154 (Italy), VAT 08931860962. For any requests regarding the processing of your personal data, please email us at firstname.lastname@example.org.
Our Data Protection Officer can be contacted for any requests relating to the processing of your personal data or this Policy by sending an email to email@example.com.
We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all the below information may be deemed personal data in your jurisdiction in all cases.
|Purpose||Legal basis||Categories of processed data|
|To enable you to use our Website and to provide you with information about it, and to process any requests you send to us when you contact us.||Processing is necessary to take steps at your request prior to entering into a contract or for the performance of a contract to which you are party (art. 6(1)(b) of the GDPR).||Identification and contact information (such as name and email address), ID and technical information on your device, your web browser details, and your IP address, and similar technologies, and other information you provide us through our Website, for example, when you submit a request for information or when you contact our customer support.|
|To comply with our legal obligations and any other obligations arising out of the instructions received from the authorities.||Compliance with a legal obligation to which we are subject (art. 6(1)(c) of the GDPR).||Any information necessary to ensure the performance of these purposes.|
|To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions).||The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations.||Any information necessary to ensure the performance of these purposes.|
|To create user profiles by analyzing preferences, behaviors, interests and choices expressed through the use of our products and services, also in order to use attribution data to measure the effectiveness of our campaign and make our advertising more relevant.||The legal basis for the processing is your consent (art. 6(1)(a) of the GDPR and/or, where appropriate, art. 5(3) of the e-Privacy Directive)||Identifiers and Internet and network activity information (such as IP address).|
We retain data collected through the use of our website for as long as necessary to carry out the purposes indicated above and in accordance with applicable laws. To know how long your data is stored through cookies and similar technologies, see Section 8 (Cookies) below.
Providing navigation data is necessary if you want to navigate and interact with our Website. Same goes for the information you share with us when you contact us to request information or support. You can freely decide whether to accept cookies and other tracking technologies not strictly necessary for the functioning of the Website as indicated in Section 8 (Cookies) below.
We may share or disclose your personal data to the following categories of recipients:
We may transfer your personal data from the European Economic Area (“EEA”) to other countries outside the EEA (e.g. if your personal data is collected by third parties when you accept – where appropriate – third-party cookies and/or similar technologies, who may be located outside the EEA).
Such data transfers are based on appropriate safeguards in accordance with Data Protection Laws, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) Binding Corporate Rules.
More information on the relevant data transfers, and appropriate warranties is available for consultation by sending an email to firstname.lastname@example.org.
At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Data Protection Laws:
You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
To exercise your rights, or if you have any other questions about privacy or data protection at Bending Spoons, you can contact us by sending an email to email@example.com. We may take reasonable steps to verify your identity prior to responding to your request.
What are cookies and tracking technologies?
When we use the word “cookies” in this Policy, we mean any tracking technology that stores or accesses information on the user’s device, including any SDK, tracking pixel, HTML5 local storage, local shared object, and fingerprinting technique.
Cookies are usually classified: (A) by purpose (Technical cookies, Analytics cookies, Profiling cookies); (B) by publisher (First-party cookies, Third-party cookies); and (C) by duration (Session cookies, Permanent cookies).
This classification is important because different legal requirements apply based on how the cookie is classified.
Below you will find the types of cookies and tracking technologies as classified with some practical examples.
A. By purpose
According to their purpose, cookies may be classified in the following categories:
B. By publisher
Cookies are installed directly by the website that the user is browsing. In other words, the publisher of the website installs the cookies directly without using any third-party publishers and processes the information thereby acquired.
Third-party cookies are set by external providers other than those of the website that the user is browsing. In other words, the publisher of the website installs the cookies indirectly, using third-party publishers and processes the information thereby acquired.
The data collected by these third parties is governed by their own specific privacy policies, terms and conditions, or cookie policies to which we have no control over.
When our website hosts third-party non-anonymized analytics cookies and/or profiling cookies, you will be asked to consent to such third-party cookies when landing on our websites for the first time, via a specific cookie banner.
You can manage and delete these third-party cookies at any time by accessing the privacy policies of the third parties as indicated in the following section ("Types of cookies used by the Website”).
C. By duration
Session cookies expire when the user's browsing session expires.
Permanent cookies last longer than a single browsing session.
Types of cookies used by the Website
This Website installs the types of cookies indicated in the tables above. You can customize your cookie preferences at any time by accessing the cookie management platform on our Website.
You can also disable (in whole or in part) technical cookies through the specific functions of your browser. Please note, however, that if you don’t allow technical cookies, you may not be able to use the Website, view its contents and take advantage of its services. Inhibiting technical cookies may result in some services or features of the Website not being available or not working properly and you may be required to modify or manually enter certain information or preferences each time you visit the Website.
The choices you make with respect to the Website's cookies will be recorded in a cookie. However, in some circumstances this cookie may not work properly: in such cases, we recommend that you delete the cookies you do not like and inhibit their use through the features of your browser.
Your cookie preferences will need to be reset if you use different devices or browsers to access the Website.
You can find information on how to manage cookie settings on certain browsers via the following links:
For more information about how to limit the use of third-party cookies installed in your browser, please visit www.youronlinechoices.com. Once arrived on the website, by accessing the "Your ad choices" section, you will be able to view the list of third parties that install cookies on your browser and manage your consent granularly ("On/Off"). Moreover, by expanding the "Info" section, you will be able to access to more information about each third party and its privacy and cookie policies.
With regards to your rights under applicable Data Protection Laws, please refer to Section 7 above.
We may modify or update this Policy, also in view of future changes in applicable Data Protection Laws or in case we implement new features or functionalities that will process personal data.
Last updated: 1 April 2022