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PRIVACY POLICY DECLARATION

As of 15 August 2022

 

The following data protection declaration applies to Francesca Ferraroni Holibrio / Holibrio / www.holibrio.com and its sub-domains, affiliated sites and Holibrio’s pages and accounts on Facebook, WhatsApp, LinkedIn and Instagram. (“Website”/”Site”/“Websites”/”Sites”).

 

It defines the principles according to which all personal data that we collect from you and/or that you make available to us are processed by us. We respect your privacy choices and understand your need to keep your personal information private. We are committed to safeguarding any and all information we collect from you when you make use of our Content, Services and/or Products.

If you are a User, Visitor, Viewer, Subscriber, Client, and/or Customer of our Sites (“User”, “You”, and/or “Your”), read this Privacy Policy in its entirety before using, viewing, downloading, purchasing from, or accessing our Site, Contents, Services, and/or Products.

 

By using our Sites, you consent to the terms and condition of this policy declaration.

If you do not accept it, please do not access our Sites.

 

General Information about the collection of personal data and provider identification

1.  In the following, we inform you about the collection of personal data when using the website. Personal data are all data that relates to a specific or identifiable person.  For example, name, address, e-mail addresses, user behavior, etc.

2.  Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

3. These Sites and Francesca Ferraroni Holibrio/ Holibrio are represented by Francesca Ferraroni (“I”/ “We”/ “Us”/“Our”), and located in Switzerland.   We can be contacted at info@holibrio.com.

 

What do we collect?

We collect, store and use the following personal data:

  1. Personal Identification Information (First Name, Last Name, E-mail Address, Physical Address, Telephone Number)

  2. Credit Card Information / Payment Information

  3. Billing and Shipping Address

  4. Social Media Profile Information

  5. Photos

  6. Bio

  7. Location

  8. Birthdates

  9. Gender

  10. Ethnicity and Racial Features.

  11. Medical History

  12. Physical and Mental Health Information / History

  13. Eating, Lifestyle, Professional and Personal History

  14. Contact details of another person to be contacted in case of emergency

 

We also collect store and use data pertaining to your behavior, for example, purchase data, and data from your Computer including your IP Address, Geographical Location, Browser Type, time Zone, Operating System, Browser Version, Pages in our site that you visit, time and date of visit, and time spent on those pages.

Lastly, we collect information contained in any communications that you send to us by email or through our website, including its communication content and metadata.

 

How do we collect your personal data?

In most instances, you directly provide us the data that we collect. We collect and process data when you:

  1. Register with our Sites or create an account on our websites.

  2. Subscribe to our email list or newsletter.

  3. Purchase anything from our Sites.

  4. Download anything from our Sites, including freebies, lead magnets and the like.

  5. Contact us through e-mail or through the contact button on our Sites.

  6. Participate in contests and giveaways.

  7. Enter our Sites for purpose of gaining access to courses, membership areas, blog, private groups.

  8. Leave a review or feedback

  9. Voluntarily complete a customer survey

 

We collect information about your computer including your IP address, geographical location, browser type and version, and operating system by automatic data collection technologies including Google Analytics, Cookies, and similar methods, as detailed below. This means that the moment you browse our Site, we are already collecting these data.

We collect communication content and metadata when you post it to our Sites or mobile application, and when metadata is generated by our website in connection with your communication.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

 

Why do we collect and process your personal information?

Personal data that you submit to us voluntarily, through our Site or through other means will be used to:

  1. Administer our Sites and business.

  2. Personalize our Site for you.

  3. Enable your use of the services available on our Sites.

  4. Allow you access to our private groups.

  5. Process your order.

  6. Send you goods purchased through our Sites.

  7. Supply services purchased through our Sites.

  8. Manage your account you created on our Sites.

  9. Send you statements, invoices, and payment reminders to you, and collecting payments from you.

  10. Send you non-marketing commercial communications.

  11. Send you email notifications that you have specifically requested.

  12. Send you newsletters if you subscribed to our website. You can inform us at any time if you no longer require the newsletter.

  13. Send you marketing communications relating to our business or the businesses of carefully selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology. You can inform us at any time if you no longer require marketing communications.

  14. Provide third parties with statistical information about our users.  We never provide third parties with data that will be able to identify any individual user from that information.

  15. Deal with inquiries and complaints made by or about you relating to our Site, Products or Services.

  16. Keep our Sites secure and prevent fraud.

  17. Verify compliance with the terms and conditions governing the use of our Sites including monitoring private messages sent through our Site’s private messaging service, and

  18. Comply with a legal obligation.

  19. Protect the life or physical safety of the data subject.

  20. Other uses consistent with this Privacy Policy.

 

If you submit personal information for publication on our Site, we will publish and otherwise use that information in accordance with the license you grant to us.

We will not, without your express consent, supply your personal information to any third party for their or any other third party’s direct marketing.

 

We will disclose your personal information in the following instances:

We may disclose your personal information to any of our employees, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies, subsidiaries and holding companies as reasonably necessary for the purposes set out in this policy.

We will disclose your personal information:

  1. To the extent that we are required to do so by law.

  2. In connection with any ongoing or prospective legal proceedings.

  3. To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention and reducing credit risk.

  4. To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplatin­­g) selling; and

  5. To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

 

Except as provided in this policy, we will not provide your personal information to third parties.

 

Details about our platform and service provider

www.holibrio.com  is hosted by Wix.com Ltd. (“Host”).  Our Host provides us with the online platform that allows us to host our blog, sell our products and services to you.

Your data may be stored through our Host’s data storage, databases and the general applications.

Our Host and our other service providers may use analytic tools to measure traffic and usage trends for www.holibrio.com. For example, when you visit www.holibrio.com, our Host may collect the following information from your visit:

  1. the IP address of the computer or device you are using to visit our website,

  2. date and time of access,

  3. name and URL of the data accessed,

  4. the website from which access is made to our domain,

  5. your computer's operating system and the browser you user

  6. the country from which access to our website is made and

  7. the name of your internet provider.

 

This data is stored and managed by our Host, and thus, is subject to their privacy policy. By using www.holibrio.com, you are agreeing to be bound by our Host’s privacy policy, which can be found here: www.wix.com/about/privacy.

 

International data transfers

Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

Information that we collect may be transferred and or processed in Switzerland, Italy, Ireland, Israel, United States, Germany and Netherlands.

Personal information that you publish on our Sites or submit for publication on our Sites will be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

You expressly agree to the transfers of personal information described in this Section.

 

What are your rights?

1.   Right to Access. You have a right to request from us copies of your personal information subject to the following:

a. payment of a fee of 15 CHF; and

b. the supply of appropriate evidence of your identity such as passport and national ID.

c. We may withhold personal information that you request to the extent permitted by law.

d. You may instruct us at any time not to process your personal information for marketing purposes.

2.   Right to Erasure. If you have given your consent to the use of data, you can revoke it at any time.

3.   Right to restrict processing. You have the right to request that we restrict the processing of your personal information, under certain conditions.

 

4.  The right to object processing. You have the right object to us processing of your personal information, under certain conditions.

 

5.  The right to data portability. You have the right to request that we transfer the data that we collected to another organization, or directly to you, under certain conditions.

 

6.   Right to Rectification. You have the right to request that we correct any information you believe is inaccurate.  You also have the right to request that we complete information you believe is incomplete.

 

All requests for information, requests for disclosure or objections to data processing should be sent by e-mail to info@holibrio.com.  If you make a request, we have thirty (30) days to respond to you. 

 

How we respond to “Do not Track” requests?

Note that your browser settings may allow you to automatically transmit “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context.  Like many websites and online services, we currently do not alter our practice when we receive a “Do not Track” signal from a visitor’s browser. To find more about “Do Not Track.” You may wish to visit http://www.allaboutdnt.com.

 

How long do we retain your data?

We keep data for as long as there is a need to keep it in connection with the purposes for which it was collected. We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries. 

Notwithstanding the other provisions of this, we will retain documents, including electronic documents, containing personal data:

  1. To the extent that we are required to do so by law.

  2. If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

  3. In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

 

While the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded. 

If you ask us to stop sending you marketing communications or Unsubscribe from our email list, we will retain certain details, such as your name, to help us ensure that you are not contacted again.

 

Security of your personal information

  1. www.holibrio.com uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content. Data that you transmit to us cannot be read by third parties.

  2. We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.

  3. As we are using our Host’s platform for www.holibrio.com, as such, we are limited by the processes used by our Host to protect your data, including the use of firewall and encryption for payments.

  4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

  5. You are responsible for keeping the password you use for accessing our Sites; we will not ask you for your password except when you log in to our website.

 

Cookies and Tracking Tools

Our Site uses cookies. These are small text files that make it possible to save specific, user-related information on your device while you are using our Site. Cookies make it possible for us to determine the frequency of use and the number of users of the pages of our Sites and to analyze the behavior of our Site users. They make our offers more customer friendly. 

Cookies are stored beyond the end of a browser session and can be called up again when you visit the site again. If you do not want this, you should set your internet browser so that it refuses to accept cookies.

You can also delete cookies.  If you are in the Europe, you can learn more how to delete cookies in this website: www.youronlinechoices.com 

Take note however that deleting cookies will have a negative impact on the usability of many websites.

 

We use Google Analytics

www.holibrio.com uses Google Analytics, a web analysis service from Google Ireland Limited (“Google Analytics”).

We use Google Analytics for a cross-device analysis of our visitors. We would like to point out the Google Analytics ensured an anonymous collection of IP addresses. If the data collected from you can be linked to a person, it will be excluded and deleted immediately.

It is possible that your full IP address will be sent to a Google Server in the US in exceptional cases. Google will use the information to evaluate your use of our Sites, to compile reports on our Site’s activities. If this exceptional case occurs, Google Analytics has submitted to the EU-US Privacy shield which you can read here:  https://www.privacyshield.gov/EU-US-Framework.

Google Analytics uses Cookies which you can deactivate using a plug-in for this purpose. You have to take note that if you opt to deactivate Google Analytics, you may not be able to use all functions of our Sites to their full extent.

 

Privacy Policy pertaining to Children

Our Sites are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, please do not provide any information on our Sites.

If you are parent or guardian and you are aware that your child has provided us with Personal Information, please contact us.  If we become aware that we have collected personal data from anyone under the age of 13 without verification of parental consent, we take steps to remove the information from our system.

 

Your Personal Data when you Purchase anything from our Sites

We do not collect, store, nor have access to any payment data (example, credit / debit card details) related to your purchase. We may have access to limited personal data, such as your name, email address, and which products you purchased. Furthermore, we may use this data to contact you about your purchase, but only if you have given your consent to allow us to do so.

We make use of the following payment gateways:

1.  Use of PayPal as payment method

If payment is made via the payment service provider "PayPal", the payment will be processed by PayPal and subject to PayPal’s Terms of Use, available at www.paypal.com.

Depending on the payment method selected via PayPal, the personal data transmitted to PayPal may be transferred by PayPal to credit agencies. This transmission serves the identity and credit check with regard to the order you have placed. You can find out which credit agencies are involved and which data is generally collected, processed, stored and passed on by PayPal in the PayPal privacy policy at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

 

2.  Use of instant bank transfer by Stripe

If you pay by instant bank transfer, your bank details will not be stored by us, but will be encrypted using the "SSL" method and forwarded to the payment service provider Stripe Payments. If you want to know more about Stripe’s privacy policy, you can read it here: https://stripe.com/en-ch/privacy

If you have any questions about Stripe’s privacy policy, please send a message to privacy@stripe.com.

3.  If you choose offline payment through Bank Transfer, we will have access to the following information:

 a. Your name

b.Your Phone number

c.Email address

d.You Bank Account Number

However, we do not have control nor are we responsible how Banking institutions such handle these details.

If you choose payment via Bank Transfer, your payment will be handled either by Raiffeisen Gruppe for Swiss Francs payments and Wise Europe SA for Euro payments.

 

You can read about Raiffeisen Gruppe's privacy policy here: https://www.raiffeisen.ch/content/dam/www/rch/pdf/raiffeisen-gruppe/reglemente/de/allgemeine-datenschutzerklaerung.pdf

Wise Europe SA's privacy policy can be read here: https://wise.com/gb/legal/privacy-policy-eea

 

4.  If you pay through our website using a credit card, your bank and card details will not be stored by us, but will be encrypted and forwarded to the payment service of Wix.  If you want to know more about Wix’s privacy policy, you can read it here: https://www.wix.com/about/privacy.  Wix is committed to protecting your data and it is currently complying with the Payment Card Industry Data Security Standards.

 

Use of Social Media Plug-ins

We currently use the following social media plug-ins: Instagram

We use the so-called 2-click solution. This means that when you visit our Site, no personal data is initially passed on to the providers of these plug-ins.

You can recognize the provider of the plug-in by the initial letter / symbol. Only if you click on one of the plug-ins, personal data will be transmitted: When the plug-in is activated, data is automatically transmitted to the respective plug-in provider and stored there. We have no influence on the collected data and data processing procedures, nor are we aware of the full extent of the data collection, the purposes or the storage periods. Since the plug-in provider collects data in particular via cookies, we recommend that you delete all cookies before clicking on the symbols via the security settings of your browser.

If you want to learn how our social media plug-ins provider handle your data, you can read their respective privacy policies here:

Meta Platforms Inc (Instagram), https://privacycenter.instagram.com/policy

 

Third Party Links

Our Sites may contain links to other websites that are not operated by us.  If you click on a third- party link, you will be directed to that third party’s site. We strongly advice you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

 

Our social media accounts and third party applications we use.

It is possible that you engage with us through our social media accounts and other third-party applications we use.

This privacy policy is also applicable to those engagements as far as practicable.

Take note that personal information you transmit to our social media accounts or through third party applications we use are usually not collected by us but by our social media platform providers. As such, they are governed by the privacy policies of those providers. Likewise, these providers use cookies.

If you want to know how our social media and third-party application provider use and collect your data, please read their respective privacy policies here:

Google Inc., https://policies.google.com/privacy

Meta Platforms Inc (Instagram), https://privacycenter.instagram.com/policy

LinkedIn, Inc., https://www.linkedin.com/legal/privacy-policy

Whatsapp Ireland Limited https://www.whatsapp.com/legal/privacy-policy-eea/?lang=en

Zoom https://explore.zoom.us/en/privacy/

 

Our E-mail Policy

If you elect to communicate to us via email, we may retain the content of your communications, including your email address. These communications are afforded the same protection as laid out in this privacy policy.

All emails sent to us are confidential. We do not disclose, sell, transfer, or otherwise lease our email list to any third parties, nor will disclose our email list to any third party, except in cases stated in this privacy policy.

In compliance with the provisions of the US CAN-SPAM Act, all emails from us will clearly state the sender’s name, clear and specific information as to how to contact us. Our emails will also provide specific instructions in case you wish to unsubscribe from our email list.

 

Amendments to the data protection declaration

We reserve the right to amend the data protection declaration to adapt it to changed legal situations or in the event of changes to the services offered and data processing. However, this only applies with regard to statements on data processing. If the consent of the users is required or if elements of the data protection declaration contain regulations of the contractual relationship with the users, the changes are only made with the consent of the users.

The users are asked to inform themselves regularly about the content of the data protection declaration.

If you have questions or complaints about this Privacy Policy, contact us at info@holibrio.com.

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