PRIVACY POLICY

TÈNUA collects some Personal Data from its Users.

This document contains a section dedicated to Users in the United States and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Policy summary

Personal Data processed for the following purposes and using the following services:

• • Access to third party services' accounts

    • Facebook account access

      Permissions: Contact email

    • Access to the Twitter account, Stripe account access and Google Drive account access

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Advertising

    • Direct Email Marketing (DEM)

      Personal Data: email address

    • Google Ads conversion tracking, Meta ads conversion tracking (Meta pixel), X Ads conversion tracking and Yahoo Advertising conversion tracking

      Personal Data: Trackers; Usage Data

    • Microsoft Advertising, Criteo, Ligatus, Tradedoubler, Google Ad Manager, Yahoo App Publishing Advertising, Rai Pubblicità, RCS MediaGroup Advertising and IlSole24Ore Advertising

      Personal Data: Cookies; Usage Data

    • Outbrain

      Personal Data: Cookies; various types of Data as specified in the privacy policy of the service

    • Facebook Audience Network

      Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

    • LinkedIn conversion tracking (LinkedIn Insight Tag) and Pinterest Conversion Tag

      Personal Data: device information; Trackers; Usage Data

    • Pinterest Ads

      Personal Data: Tracker

  • Analytics

    • Google Analytics (Universal Analytics), Display Advertising extension for Google Analytics, KISSmetrics, Wordpress Stats, HubSpot Analytics, Salesforce Analytics Cloud and Google Analytics (Universal Analytics) with anonymized IP

      Personal Data: Cookies; Usage Data

    • User ID extension for Google Analytics

      Personal Data: Cookies

    • Facebook Analytics for Apps

      Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

    • Matomo

      Personal Data: Tracker; Usage Data

    • YouTube Analytics and Reporting API

      Personal Data: Tracker

    • DOMO

  • Backup saving and management

    • Backup on Google Drive and Backup on Dropbox

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Commercial affiliation

    • ReferralCandy

      Personal Data: Cookies; email address; first name; last name; Usage Data

  • Contacting the User

    • Mailing List or Newsletter

      Personal Data: email address

    • Phone contact

      Personal Data: phone number

    • Contact form

      Personal Data: address; city; company name; country; date of birth; email address; field of activity; first name; gender; last name; phone number; profession; Tax ID; User ID; various types of Data; VAT Number; ZIP/Postal code

  • Content commenting

    • Comment system managed directly

      Personal Data: Cookies; email address; first name; last name

    • Disqus

      Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service

  • Content performance and features testing (A/B testing)

    • Google Optimize

      Personal Data: Cookies; Usage Data

  • Data transfer outside the EU

    • Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield, Data transfer to countries that guarantee European standards, Data transfer abroad based on consent, Data transfer abroad based on standard contractual clauses and Other legal basis for Data transfer abroad

      Personal Data: various types of Data

  • Device permissions for Personal Data access

    • Device permissions for Personal Data access

      Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; Calendar permission; Camera permission; Contacts permission; HomeKit permission; Microphone permission; Motion sensors permission; Phone permission; Precise location permission (continuous); Precise location permission (non-continuous); Reminders permission; Sensors permission; SMS permission; Social media accounts permission; Storage permission

  • Displaying content from external platforms

    • Google Fonts

      Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

    • Google Maps widget, Vimeo video, Instagram widget and YouTube video widget

      Personal Data: Cookies; Usage Data

  • Handling payments

    • PayPal, Klarna, SOFORT, Stripe, Apple Pay, Amazon Payments and PayPal Payments Hub

      Personal Data: various types of Data as specified in the privacy policy of the service

    • PayPal Carrier Payments

      Personal Data: phone number; various types of Data as specified in the privacy policy of the service

  • Handling productivity related activity

    • Google Workspace

      Personal Data: Data communicated while using the service

  • Hosting and backend infrastructure

    • Amazon Web Services (AWS)

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Infrastructure monitoring

    • Pingdom

      Personal Data: Cookies; Usage Data

    • Bugsnag

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Interaction with data collection platforms and other third parties

    • Mailchimp widget

      Personal Data: Cookies; email address; first name; last name

  • Interaction with external social networks and platforms

    • PayPal button and widgets, Facebook Like button and social widgets, LinkedIn button and social widgets, Google+ +1 button and social widgets and Twitter Tweet button and social widgets

      Personal Data: Cookies; Usage Data

  • Interaction with live chat platforms

    • Facebook Messenger Customer Chat

      Personal Data: About Me; Cookies; Data communicated while using the service; Usage Data

    • Freshchat Widget

      Personal Data: Cookies; Data communicated while using the service; email address; Usage Data

    • Zendesk Chat

      Personal Data: Data communicated while using the service

  • Interaction with support and feedback platforms

    • Zendesk Widget

      Personal Data: email address

  • Location-based interactions

    • Geolocation

      Personal Data: geographic position

  • Managing contacts and sending messages

    • Mailchimp, MailUp and ZOHO Campaigns

      Personal Data: email address

    • HubSpot Email

      Personal Data: email address; Usage Data

    • OneSignal

      Personal Data: email address; geographic position; language; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service

  • Managing landing and invitation pages

    • Mailchimp Landing Page

      Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username

    • Leadpages

      Personal Data: email address; Usage Data; various types of Data as specified in the privacy policy of the service

  • Managing support and contact requests

    • Freshdesk, Salesforce Service Cloud, ZOHO CRM Email and Zendesk

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Platform services and hosting

    • Shopify, Tumblr and WordPress.com

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Registration and authentication

    • Facebook Authentication, Twitter OAuth, Google OAuth, Log In with PayPal, Login with Amazon, Mailchimp OAuth, Stripe OAuth, Linkedin OAuth and Instagram Authentication

      Personal Data: various types of Data as specified in the privacy policy of the service

    • Direct registration

      Personal Data: address; email address; first name; last name; password; phone number

  • Remarketing and behavioral targeting

    • Facebook Remarketing, AdRoll, Remarketing with Google Analytics, Google Ads Remarketing, Twitter Remarketing, Google Ad Manager Audience Extension, Criteo Dynamic Retargeting and LinkedIn Website Retargeting

      Personal Data: Cookies; Usage Data

    • Facebook Custom Audience and Twitter Tailored Audiences

      Personal Data: Cookies; email address

  • Social features

    • Inviting and suggesting friends

      Personal Data: Various types of Data

  • SPAM protection

    • Google reCAPTCHA

      Personal Data: Cookies; Usage Data

  • Tag Management

    • Google Tag Manager

      Personal Data: Usage Data

    • Segment

      Personal Data: Tracker; Usage Data

  • Traffic optimization and distribution

    • jsDelivr

      Personal Data: Usage Data

  • User database management

    • FullContact

      Personal Data: company name; date of birth; Email; first name; gender; last name; various types of Data as specified in the privacy policy of the service

    • HubSpot CRM

      Personal Data: email address; phone number; various types of Data as specified in the privacy policy of the service

    • HubSpot Lead Management, Salesforce Marketing Cloud and Salesforce Sales Cloud

      Personal Data: various types of Data as specified in the privacy policy of the service

    • ZOHO CRM

      Personal Data: email address; various types of Data as specified in the privacy policy of the service

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• • TikTok

    https://www.tiktok.com/legal/privacy-policy

  • DOMO

    https://www.domo.com/company/privacy-policy

  • DOMO

    https://www.domo.com/company/privacy-policy

  • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by TÈNUA depends on the payment system used.

  • Unique device identification

    TÈNUA may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • User identification via a universally unique identifier (UUID)

    TÈNUA may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

  • Analysis and predictions based on the User’s Data (“profiling”)

    The Owner may use the Personal and Usage Data collected through TÈNUA to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
    User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
    The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

  • Personal Data collected through sources other than the User

    The Owner of TÈNUA may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
    Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

  • Privacy Shield participation: data transfers from the EU and Switzerland to the United States

    The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

    If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

    What does this mean for the European User?

    The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

    This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

    The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

    With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

    The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    Dispute resolution under the Privacy Shield

    In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

    In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

    In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

    Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

  • Automated decision-making

    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. TÈNUA may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. TÈNUA adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
    Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
    The rationale behind the automated decision making is:

    • to enable or otherwise improve the decision-making process;

    • to grant Users fair and unbiased treatment based on consistent and uniform criteria;

    • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;

    • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within TÈNUA, Users can check the relevant sections in this document.

    Consequences of automated decision-making processes for Users and rights of Users subjected to it

    As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
    In particular, Users have the right to:

    • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;

    • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;

    • request and obtain from the Owner human intervention on such processing.

    To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Contact information

Owner and Data Controller

PHANTASMA S.R.L.
via Ugo La Malfa 1, 20017 Milano, Italia
C.F./P.IVA: IT 10839240966
PEC: phantasmasrl@pec.it
info@phantasma-inc.com
 

Full policy

Owner and Data Controller

PHANTASMA S.R.L.
via Ugo La Malfa 1, 20017 Milano, Italia
C.F./P.IVA: IT 10839240966
PEC: phantasmasrl@pec.it
info@phantasma-inc.com
 

Types of Data collected

Among the types of Personal Data that TÈNUA collects, by itself or through third parties, there are: Cookies; Usage Data; email address; Various types of Data; first name; last name; phone number; address; password; date of birth; Email; gender; company name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; device information; VAT Number; profession; country; ZIP/Postal code; city; Tax ID; field of activity; User ID; username; About Me; Data communicated while using the service; Calendar permission; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Phone permission; Sensors permission; SMS permission; Storage permission; Reminders permission; HomeKit permission; Motion sensors permission; Bluetooth sharing permission; Social media accounts permission; language.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using TÈNUA.
Unless specified otherwise, all Data requested by TÈNUA is mandatory and failure to provide this Data may make it impossible for TÈNUA to provide its services. In cases where TÈNUA 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.
Any use of Cookies – or of other tracking tools — by TÈNUA or by the owners of third-party services used by TÈNUA serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through TÈNUA.

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 TÈNUA (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.

Place

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.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Registration and authentication, Remarketing and behavioral targeting, Access to third party services' accounts, Analytics, Contacting the User, Advertising, Managing contacts and sending messages, Hosting and backend infrastructure, Social features, Handling payments, Managing support and contact requests, Displaying content from external platforms, Tag Management, Content performance and features testing (A/B testing), Interaction with external social networks and platforms, Platform services and hosting, Backup saving and management, Content commenting, Interaction with data collection platforms and other third parties, User database management, Location-based interactions, SPAM protection, Commercial affiliation, Managing landing and invitation pages, Interaction with live chat platforms, Infrastructure monitoring, Device permissions for Personal Data access, Data transfer outside the EU, Traffic optimization and distribution, Handling productivity related activity and Interaction with support and feedback platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by TÈNUA

TÈNUA may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows TÈNUA to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Contact email

Access the user's contact email address.

Device permissions for Personal Data access

Depending on the User's specific device, TÈNUA may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of TÈNUA.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by TÈNUA.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. TÈNUA may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. TÈNUA may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for TÈNUA to derive the approximate position of the User on a continuous basis.

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

Calendar permission

Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

HomeKit permission

Used for accessing the HomeKit framework and enabling this app to interact with physical accessories in the User's surrounding environment.

Microphone permission

Used for accessing and recording microphone audio from the User's device.

Motion sensors permission

Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Precise location permission (continuous)

Used for accessing the User's precise device location. TÈNUA may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. TÈNUA may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for TÈNUA to derive the exact position of the User on a continuous basis.

Reminders permission

Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.