PRIVACY POLICY – MCP

In compliance with the obligations deriving from the national (Privacy Code) and community legislation (European General Regulation n. 679/2016) regarding the protection of personal data, Mindful Capital Partners ( “MCP” or “We”) respects and protects the privacy of visitors and users.

This privacy statement applies both to the collection of information from the website and from other channels.

1 – LEGAL BASIS OF THE PROCESSING

We use the information that we collect from you in our legitimate interests to assist us in providing our services to you or in the case of our promotional or marketing communications to you, where we have your consent. In addition to this, we may also use the information for one or more of the following purposes and lawful grounds:
Information we collect from you:
i. To contact you in our legitimate interests, in situations where you have asked us to do so, (for example if you request via the Site that we phone you);
ii. To provide you with information which you have requested from us in our legitimate interest or, where required with your consent. (For example, if you request a product sheet or newsletter from us);
iv. To provide information to you relating to other services that may be of interest to you. Such additional information will only be provided where you have separately consented to receive such information.
v. To obtain in our legitimate interest or where required by national law or with your consent, your feedback on our services which may include by way of a market research survey..

2 – PURPOSE OF THE TREATMENT

Personal data processing means: registration, storage, organization, consultation, selection, extraction, comparison, processing, use, modification, interconnection, blocking, communication, cancellation and destruction, transfer or diffusion, or the combination of two or more such operations.
The processing of data collected by the site, in addition to the related, instrumental and necessary purposes for providing the service, is aimed at the following purposes:

2.1 – STATISTICS

Collection of data and information in an exclusively aggregated and anonymous form in order to verify the correct functioning of the site, to improve the online store and the platform.
None of this information is related to the physical person-user of the site, and does not allow identification in any way.

2.2 – SECURITY

Collection of data and information in order to protect the safety of the site and users (spam filters, firewalls, virus detection) and to prevent or unmask fraud or abuse to the detriment of the website.
The data are recorded automatically and may possibly also include personal data (IP address) which could be used, in accordance with the laws in force on the subject, in order to block attempts to damage the site itself or to damage other users, or in any case harmful activities or constituting a crime. These data are never used for the identification or profiling of the User and are periodically deleted.

2.3 – MARKETING / ADVERTISING

Collection of data and information in general and in particular on the orientations and preferences of the User; send information and advertising material, including from third parties; send commercial communications, including interactive ones; carry out direct sales or placement of products or services; to develop studies and statistical research on sales, customers and other information, and possibly communicate the same to third parties; transfer the data collected and processed for commercial purposes to third parties also for sale or attempted sale, or for all those purposes of a commercial and / or statistic lawful nature, publish reviews of our services.

These data, including possibly the IP and other identification data, are used in order to allow third parties to send advertisements relevant to the User’s interests through this site to the User’s browser and to measure the effectiveness of advertising messages. These advertisements can also be presented on other sites in the advertising circuit (remarketing or retargeting).

The advertisements published on the site are provided on the basis of agreements with third-party companies, which use data collected from them directly, for which collection our site acts as a mere intermediary. These data do not include the name, address, email address or telephone number, and are used to provide personalized advertisements on products and services. For more information on these services, please read the information provided by third-party companies, which also indicate the options to possibly disable the collection of information by these companies.

More information on the following web pages:
– Google advertising circuit: https://www.google.com/policies/technologies/ads/
– Facebook advertising circuit: https://www.facebook.com/about/privacy/

2.4 – SHOPPING / SUPPLY OF SERVICES

Collection of data to manage orders, provide products and services, process payments, communicate with users about orders, products, services and promotional offers, update registers and, in general, manage users’ accounts, show content such as lists customer wishes and reviews and recommend products and services that may be of interest to users.

2.5 – ANCILLARY ACTIVITIES

Communicate data to third parties that perform functions necessary or instrumental to the operation of the service, and to allow third parties to carry out technical, logistical and other activities on our behalf.
This site uses suppliers to carry out certain activities, such as processing orders, delivering parcels, sending traditional mail, analyzing data, providing marketing assistance, making payments with credit cards and providing customer services.
Suppliers have access only to personal data that are necessary to perform their duties, and undertake not to use the data for other purposes, and are required to process personal data in accordance with current regulations.

This category of data is kept only for the period of time necessary for the provision of the service.

3 – DATA COLLECTED

This site collects user data in two ways.

3.1 – DATA COLLECTED IN AN AUTOMATED MANNER

While users are browsing, the following information can be collected which is kept in the site’s log files:

• Internet protocol (IP) address;
• Browser type;
• Device parameters used to connect to the site;
• Name of the internet service provider (ISP);
• Visit date and time;
• Web page of origin of the visitor (referral) and of
• Exit;
• Possibly the number of clicks.

These data are used to analyze user trends and collect data in aggregate form, administer and guarantee the security of the site, and are in no way attributable to the identity of the User.

3.2 – DATA PROVIDED VOLUNTARILY

The site may collect other data in case of voluntary use of services by users, such as comments, communication services (chat, contact forms and email sending), purchase (cart):

• name and surname;
• date of birth;
• email address;
• physical residence address;
• VAT number and / or tax code;
• credit card number and / or current account and / or IBAN;
• company and headquarters;
• image (avatar);
• social profiles;
• geographic location.

These data are provided voluntarily by the User when requesting the service, or when entering the comment, and will only be used for the provision of the requested service and processed only for the time necessary to provide the service.
The email address is also used in order to send promotional material to users who are already customers, therefore in the context of an existing commercial relationship. The customer can always oppose the sending of such communications. For users who are not yet customers, the sending of promotional material is subject to the collection of consent, which can be revoked later.
Tax data are necessary in order to take advantage of paid services, and for billing purposes.
The data collected by the site are not provided to third parties, unless it is a legitimate request by the judicial authority and only in the cases provided for by law. However, the data may be provided to third parties if this is necessary for the provision of a specific service requested by the User, or for tax purposes or for carrying out security checks or site optimization.

5 – DATA RETENTION PERIOD

The collected data are processed for the times necessary for the purposes for which they were collected, and in any case not beyond the times prescribed by law.
The data necessary for tax purposes are kept until the assessments relating to the corresponding tax period are defined, therefore for at least 10 years and more if the relative year is not yet prescribed for tax purposes.
Upon expiry, the data will be deleted or anonymised, unless there are additional purposes for the conservation of the same (e.g. guarantee supply obligations, tax obligations).

6 – TRANSFER OF DATA COLLECTED TO THIRD PARTIES AND TO NON-EU COUNTRIES

MCP’s business is international and MCP may therefore need to transfer your personal data to third parties located in countries which may not provide appropriate or suitable safeguards. Transferees will include third parties noted in section (7) above as well as other members within the MCP group. Where we transfer your data outside the European Economic Area we will do so on the basis of: (i) an adequacy decision; (ii) model contract clauses; or (iii) another valid transfer mechanisms.

For more information about the safeguards applied by MCP to international transfers, please contact MCP.

7 – COOKIE

This site uses cookies and similar technologies. Cookies allow you to store information on visitor preferences, allow you to verify the correct functioning of the site and improve its functionality by customizing the content of the pages based on the type of browser used, or to simplify navigation by automating the procedures (e.g. Login, site language) and for the analysis of the use of the site by visitors.
This site uses the following categories of cookies:

Technical cookies

The cookies in this category include both persistent cookies and session cookies, allow you to distinguish between connected users avoiding that a service is provided to the wrong User and therefore are a consequence of an express request from the user, and are also used for security of the site and of the users themselves. Without these cookies, the site or some portions of it may not work properly. Cookies in this category are always sent from our domain, and consent is not required for them.

Analytical cookies

Cookies in this category are used to collect information on the correct use of the site and on user behavior for statistical analysis purposes, to improve the site and simplify its use. This type of cookie collects anonymous information on the activity of users on the site and on the way in which they arrived at the site and the pages visited. Cookies in this category are sent from the site itself or from third-party domains.

Third party cookies

This site also acts as an intermediary for third-party cookies, used to provide additional services and features to visitors and to improve the use of the site itself, such as buttons for social media. Some of these cookies are profiling, i.e. used by third parties to collect information on user behavior and interests in order to provide personalized advertising.

7.1 – CONSENT FOR THE USE OF COOKIES

By using the site, continuing to browse the site, or by clicking on the banner present at the first access to the site, the visitor expressly consents to the use of cookies and similar technologies, and in particular to the registration of these cookies on his terminal for the above purposes indicated, or when accessing cookies to information on your terminal.

7.2 – REFUSAL OR REVOCATION OF CONSENT TO COOKIES

The user can refuse the use of cookies and at any time can revoke a consent already provided. Since cookies are connected to the browser used, THEY CAN BE DISABLED DIRECTLY BY THE BROWSER, thus refusing / withdrawing consent to the use of cookies.
DISABLING COOKIES COULD PREVENT THE CORRECT USE OF SOME FUNCTIONS OF THE SITE ITSELF, in particular the services provided by third parties may not be accessible, and therefore may not be viewable: YouTube videos or other video sharing services; the social buttons of the social networks; Google maps.

Instructions for disabling cookies via a browser, and for the possible elimination of cookies already present on the user’s device, are found on the following web pages:

Mozilla Firefox

https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie

Windows Internet Explorer

https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer

Google Chrome

https://support.google.com/chrome/answer/95647?hl=it

Opera

http://help.opera.com/Windows/10.00/it/cookies.html

Apple Safari

https://support.apple.com/it-it/HT201265

You can find more information about cookies and how to manage them by consulting the website www.aboutcookies.org.

7.3 – THIRD PARTY COOKIES

This privacy policy does not apply to services provided by third parties, and this site has no control over their cookies, entirely managed by third parties, and has no access to the information collected through these cookies. As a consequence of this, information on the use of third-party cookies, on their purposes, as well as on how to disable them, are provided directly by the third parties on the pages indicated below.
Generally, the tracking of users does not involve identification of the same, unless the User is already registered with the service and is also already logged in, in which case it is understood that the User has already expressed his consent directly to the third party to the when registering for the relevant service (eg Facebook).

In particular, this site uses cookies from the following third parties.

7.3.1 – GOOGLE INC.

– Google Analytics: web analysis tool used in order to allow us to examine the use of the site by users, compile reports on site activities and user behavior, check how often users visit the site, how the site is visited tracked and which pages are visited most frequently. The information is combined by Google with information collected from other sites in order to create a comparative picture of the use of the site compared to other sites in the same category.
Collected data: browser identification, date and time of interaction with the site, page of origin, IP.
Place of data processing: USA.
The data collected do not allow personal identification of users, and are not crossed with other information relating to the same person. They are processed in aggregate and anonymized form (truncated at the last octet). According to a specific agreement, Google Inc. is prohibited from crossing these data with those obtained from other services.

– DoubleClick: a subsidiary of Google Inc. that provides online advertising services tailored to the behavior and interests of users. Cookies (DART cookies) are set when accessing a site that contains DoubleClick advertising (AdSense), and are used to publish personalized ads based on the interests of the User on this site, and to prevent the ads from being repeated.
Collected data: user behavior, start and end pages on the site, exit pages, IP address, browser data, device data, operating system, provider, date and time,
Place of data processing: USA.
DoubleClick cookies do not contain information that allows users to be personally identified. Sometimes the cookie contains an additional identifier used only to identify an advertising campaign to which a User has previously been exposed.

– Google Maps: Google service that offers road maps and location for urban businesses. Set cookies on the pages of the maps.
Collected data: number and behavior of the users of the maps, information relating to the page displayed, preferences on the display (zoom level, etc …).
Place of data processing: USA.

– Youtube: platform, owned by Google, for sharing videos. Cookies are set when accessing the page containing the embed, and when the video is started, and do not allow the identification of the User unless he is already logged in the Google profile, in which case it is intended that the User has already expressed consent directly to Google.
For some videos on the site, the “advanced privacy https://support.google.com/youtube/answer/171780?expand=PrivacyEnhancedMode#privacy (no cookie)” option has been activated which does not provide for the storage of visitor information unless they voluntarily play the video.
Data collected: number and behavior of users of the service, IP address, information linking visits to the site to the Google account for users already logged in, preferences for viewing videos.
Place of data processing: USA.
Disabling Google Inc. cookies
The data transmitted to Google is stored on Google’s servers in the United States. For more information on the use of data and their processing by Google, it is recommended to read Google’s information at the following internet address: https://www.google.com/intl/it/policies/privacy/.

Further information on Google Analytics cookies can be found on the following page: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

The User can selectively disable the action of Google Analytics by installing the appropriate component provided by Google on his browser (opt out). To disable the collection of data by Google Analytics, please refer to the following link: https://tools.google.com/dlpage/gaoptout.
The User can selectively disable the DoubleClick DART Cookie by preventing its connection with his browser, to the appropriate web page: https://adssettings.google.it/authenticated?hl=it#display_optout.

7.3.2 – FACEBOOK

– Remarketing and Custom Audience: set to publish personalized ads based on the interests of the User present on the site. Even some Facebook advertising partners can use cookies and similar technologies to track users.
Place of data processing: USA.
Facebook privacy policy: https://www.facebook.com/about/privacy/.
For more information on the use and purpose of cookies by Facebook, it is recommended to view the information at the following web address: https://www.facebook.com/help/cookies/update.

The User can selectively disable the action of Facebook Remarketing on the appropriate web page of the Digital Advertising Alliance: http://optout.aboutads.info/.

7.3.3 – PAYPAL INC.

– PayPal uses cookies to allow the correct execution of payments. Set cookies when accessing the payment form in order to: process transactions and provide PayPal services; verify the identity of the User, also during the account creation and password reset procedures; resolve disputes, collect rates and solve problems; manage risks or identify, prevent and / or remedy fraud or other potentially illegal or prohibited activities; identify, prevent or remedy violations of the rules or related agreements with users; provide the Customer with customer support services; improve PayPal Services by customizing the User experience; measure the performance of the PayPal Services and improve related content and layout; manage and protect its IT infrastructures; send targeted marketing and advertising communications, provide service updates and promotional offers based on the communication preferences defined in the PayPal account and the User’s activities while using the PayPal Services; perform solvency checks, compare the data to establish their accuracy, and verify them with third parties.
Collected data: user behavior, IP address, browser data, device data, location data, operating system, provider, date and time, name and surname, credit card number and / or current account; email address.
Place of data processing: USA.
For more information on the use and purposes of cookies by PayPal, it is recommended to view the information at the following web address: https://www.paypal.com/it/webapps/mpp/ua/privacy-full.
DISABLING PAYPAL COOKIES MAY RESULT IN THE IMPOSSIBILITY OF PROCESSING PAYMENTS AND THEREFORE PROVIDING SERVICES.

7.3.4 – SOCIAL PLUGIN

This site also incorporates plugins and / or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins do not set a cookie, but if it is already present on the visitor’s computer they are able to read it and use it according to its settings. The collection and use of information by these third parties are governed by their respective privacy policies to which please refer.

Facebook
https://www.facebook.com/about/privacy/ (cookie information link https://www.facebook.com/help/cookies/)
Twitter
https://twitter.com/privacy?lang=it (cookie information link https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte -of-twitter
LinkedIn
https://www.linkedin.com/legal/privacy-policy (cookie information link https://www.linkedin.com/legal/cookie-policy)
Google+
https://www.google.com/intl/it/policies/privacy// (cookie information link https://www.google.it/intl/it/policies/technologies/cookies/)
7.3.5 – SKYPE

This site also incorporates Skype chat in order to allow a dialogue with customers. Skype sets cookies to recognize the user, and customize the Skype web pages.
You can disable Skype cookies from the browser: open Skype and select Skype> Privacy, then uncheck the box Accept Skype cookies for the browser. Click on Save. By deactivating Skype cookies, some chat features may not be available.
Further information on Skype cookies can be found at: https://support.skype.com/it/faq/FA1390/cosa-sono-i-cookie-di-skype.

8 – SECURITY MEASURES

The Data Controller processes the data of visitors / users in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data, as well as illicit use of data. The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated, and the data is stored and stored in secure structures with limitations on access and staff verification. Access to information is strictly limited to authorized personnel.
The website is constantly monitored to check for security breaches and to ensure that information is secure.
In addition to the Owner, in some cases, categories of agents involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, may have access to the data). hosting provider, IT companies, communication agencies).

It is important that you adopt suitable protections against unauthorized access to your password and your computer. Always make sure that you are signed out when using a computer shared with other users.

9 – USER RIGHTS

Pursuant to art. 7 of Legislative Decree 30 June 2003, n. 196 http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1311248 and of the General Regulations for the protection of personal data, the User can, according to the modalities and within the limits foreseen by current legislation:

object in whole or in part, for legitimate reasons, to the processing of personal data concerning him for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication;
Request confirmation of the existence of personal data concerning him;
Know its origin;
Receive intelligible communication;
Have information about the logic, methods and purposes of the treatment;
request its updating, correction, integration, cancellation, transformation into anonymous form, blocking of data processed in violation of the law, including those no longer necessary for the pursuit of the purposes for which they were collected;
in cases of consent-based processing, receive the data provided to the owner, in a structured and readable form by a data processor and in a format commonly used by an electronic device, only at the cost of any support
the right to lodge a complaint with the Supervisory Authority (Privacy Guarantor – link to the Guarantor page http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524);
As well as, more generally, exercise all the rights that are recognized by the current provisions of the law.

Requests should be addressed to the Data Controller.

10 – SUBJECTS OF THE TREATMENT

The data controller pursuant to applicable laws is: MCP with registered office in 10, rue Antoine Jans L-1820 Luxembourg, which can be contacted at the email corporate@mcpinvest.com, or at the specified address.

Responsible for the treatment in accordance with current laws is: MCP which can be contacted at the email corporate@mcpinvest.com, or at the specified address.

11 – UPDATES

This privacy policy is updated on May 31, 2023.