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PRIVACY POLICY

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TUSAH VALUES YOUR PRIVACY. WE WILL NEVER SELL YOUR INFORMATION TO A THIRD PARTY UNDER ANY CIRCUMSTANCES. OUR WEBSITE USES COOKIES, WHICH WE USE TO BETTER UNDERSTAND YOU AND TAILOR YOUR EXPERIENCE BASED ON YOUR SHOPPING PREFERENCES. WE RESPECT YOUR RIGHT TO OPT OUT FROM OUR ADVERTISING, AND WANT TO MAKE IT AS EASY AS POSSIBLE. TO REQUEST DELETION, SEND EMAILUS AT INFO@TUSAH.COM AND WE WILL REMOVE YOU FROM OUR MARKETING DATABASE.

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THANK YOU FOR CHOOSING TUSAH.



TUSAH COLLECTS DATA USING THESE SERVICES:

  • ANALYTICS

    • GOOGLE ANALYTICS, FACEBOOK ADS CONVERSION TRACKING (FACEBOOK PIXEL) AND GOOGLE ADS CONVERSION TRACKING
      Personal Data: Cookies (*Cookies are small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. Cookies were designed to be a reliable mechanism for websites to remember information or to record the user's browsing activity); Usage Data (*Usage data is consumer behavior and preferences, this is used to tailor advertising to behavior and preferences)

  • ADVERTISING

    • GOOGLE ADS, FACEBOOK ADS

  • MANAGING CONTACTS AND SENDING MESSAGES

  • HUBSPOT EMAIL
    Personal Data: email address; Usage Data

  • REMARKETING AND BEHAVIORAL TARGETING

    • FACEBOOK REMARKETING AND GOOGLE ADS REMARKETING

  • TAG MANAGEMENT

  • GOOGLE TAG MANAGER

  • USER DATABASE MANAGEMENT

    • HUBSPOT LEAD MANAGEMENT, MAILCHIMP
      Personal Data: various types of Data as specified in the privacy policy of the service


WHAT DATA DOES TUSAH COLLECT?
 

Among the types of Personal Data that this Website collects, by itself or through third parties such as Google or Facebook, there are: Cookies; Usage Data; email address.
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 this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 this Website or by the owners of third-party services used by this Website 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, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.
Century does not sell personal information to third parties.
 

HOW TUSAH USES YOUR 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 this Website (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 or California data protection law(s).

  • 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.
 

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.
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.
 

RETENTION TIME
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

  • 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.
Personal Data is collected for the following purposes and using the following services:
 

ADVERTISING
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting

GOOGLE ADS CONVERSION TRACKING (GOOGLE INC.)
Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Website. Personal Data collected: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • ANALYTICS
    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 (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 this Website, 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.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

  • 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 this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • GOOGLE ADS CONVERSION TRACKING (GOOGLE INC.)
    Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Website.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • COMMERCIAL AFFILIATION
    This type of service allows this Website to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
    Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
    For details of which data are collected, please refer to the privacy policy of each service.
    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.

  • HUBSPOT EMAIL (HUBSPOT, INC.)
    HubSpot Email is an email address management and email message sending service provided by HubSpot, Inc.
    Personal Data collected: email address; Usage Data.
    Place of processing: United States – Privacy Policy.

  • REMARKETING AND BEHAVIORAL TARGETING
    This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website 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.
    In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  • FACEBOOK REMARKETING (FACEBOOK, INC.)
    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

  • GOOGLE ADS REMARKETING (GOOGLE LLC)
    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
    Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
    Personal Data collected: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  • TAG MANAGEMENT
    This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
    This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  • GOOGLE TAG MANAGER (GOOGLE LLC)
    Google Tag Manager is a tag management service provided by Google LLC.
    Personal Data collected: Usage Data.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • USER DATABASE MANAGEMENT
    This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

  • HUBSPOT LEAD MANAGEMENT (HUBSPOT, INC.)
    HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
    Personal Data collected: various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

YOUR RIGHTS AS A USER
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. Opt out here.

  • 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. Opt out here.

  • 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.

 

HOW TO OPT OUT
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. Opt out here.
 

DETAILED COOKIE POLICY
This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
ADDITIONAL INFORMATION ABOUT DATA USAGE
 

LEGAL ACTION
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
 

ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
 

SYSTEM LOGS AND MAINTENANCE
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
 

INFORMATION NOT CONTAINED IN THIS POLICY
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
 

CHANGES TO THIS PRIVACY POLICY
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
 

DEFINITIONS & REFERENCES
 

PERSONAL DATA (OR DATA)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
 

USAGE DATA
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
 

USER
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
 

DATA SUBJECT
The natural person to whom the Personal Data refers.
 

DATA PROCESSOR (OR DATA SUPERVISOR)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
 

DATA CONTROLLER (OR OWNER)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
 

THIS WEBSITE (OR THIS APPLICATION)
The means by which the Personal Data of the User is collected and processed.
 

SERVICE
The service provided by this Website as described in the relative terms (if available) and on this site/application.
 

EUROPEAN UNION (OR EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
 

COOKIES
Small sets of data stored in the User's device.
 

LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation) AND the California Consumer Privacy Act of 2018 (CCPA).
This privacy policy relates solely to this Website, if not stated otherwise within this document.
 

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
Under the California Consumer Privacy Act of 2018 (CCPA), consumers are granted the following new rights respecting their personal information:

  1. The right to request disclosure of Century's data collection and sales practices in connection with the requesting consumer, including the categories of personal information we have collected, the source of the information, our use of the information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold.

  2. The right to request a copy of the specific personal information collected about them during the 12 months before their request (together with right #1, a “personal information request”);

  3. The right to have such information deleted (with exceptions); To request the erasure of your information from TUSAH database.

  4. The right to request that their personal information not be sold to third parties, if applicable

  5.  The right not to be discriminated against because they exercised any of the new rights

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