PRIVACY POLICY

Relating to the use of Tooso’s Website and Services.
Effective on August 31, 2018

0. Owner and Data Controller

Owner contact email: info@tooso.ai
If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal information, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, please contact Tooso at yourdata@tooso.ai

Or at the following physical locations:

1. Introduction to this privacy policy

The website http://www.tooso.ai and the Tooso Services (collectively “This Application”) collect some Personal Data from their Users. This Privacy Policy is intended to describe the management of This Application, with reference to the use of cookies and the processing of Personal Data of Users who consult this website and surf third parties’ websites where Tooso services are provided and our cookies are placed.

2. Types of Data collected

The types of personal information we collect and share depend on which of our services the User uses. In general, we may collect information that identifies the User, information about how the User uses our website and information that the User creates while interacting with our Services. In particular, the Personal Data that we obtain through or from:

Among the types of Personal Data that This Application collects by itself or through third parties, there are Usage Data, as defined below:

The Personal Data may be freely provided by the User, or, in case of the Usage Data, collected automatically when using This Application.

3. Cookies and Data Collection

This Application uses cookies to analyze trends and track users' Usage Data around our Websites and Services, and to gather information about our user base as a whole.
A cookie is a small piece of information that is placed on the User’s device when visiting certain websites. The User can control and limit the use of cookies at the individual browser level.
It has to be made clear that, in case the User chooses to disable cookies, the use of certain features or functions on our Websites or Services may be limited or disabled. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.
In any case, it is worth mentioning what This Application does not collect data about the identity of the User as part of the Usage Data.
In collecting the Usage Data on Clients’ websites, Tooso cannot identity the User directly and is not aware of the User’s personal details like email, name, gender or age. Data collected by This Application are referred to a unique online identifier, which refers to the browser used to browse the web pages where Tooso’s cookies are placed. In a nutshell, Tooso does not know who the User is. No sensitive information (namely, data concerning political opinions, health, sexual orientation, religious beliefs or genetic and biometric data) on the User is collected. No segments to specifically target children under 16 years old are intentionally created.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts and forms displayed prior to the data collection.

4. Use of Data

Tooso uses Personal and Usage Data to allow the functioning of This Application and to conduct internal operations, including qualitative and quantitative data analysis, testing and research. This process is necessary on the basis of our legitimate interest to improve our Services, in line with the reasonable expectations of the User. The processing of Personal and Usage Data collected through Tooso’s cookies within third parties’ webpage is carried out following the consent provided by the User.
Tooso collects the Usage Data in order to ameliorate and enhance the User’s experience related to the search activity on our Clients’ websites. The data collected by This Application is also used for reporting purposes, in order to provide our Clients with information about the browsing patterns on their websites or mobile applications and the usage of their site search interfaces to improve their performances.
Data collected is processed for purposes including:

Tooso does not collect Personal or Usage Data to display advertising. Tooso services are only aimed to refine and ameliorate the search experience on the websites or mobile applications of our Clients.
Any use of cookies – or of any other tracking tool – by This Application or by the owners of third-party services used by This Application serves the purpose of providing the Services to the User as requested by the Client, in addition to any other purposes described in the present document and in the Cookie Policy.
Personal User Data collected on our Websites through the dedicated forms are processed in order to provide feedback to the request for a demo. This processing is necessary in order to allow Tooso to fulfil the pre-contractual obligation that arises when the User sends his or her request.
A possible failure to provide the Personal Data for the fulfilment of the specified purpose, will make impossible for the User to receive any feedback about the product demo.
Personal User Data collected on our Websites might also be used to set up and manage the access to the Services to the Client and to provide the Client with notices about their account and/or subscription, including expiration and renewal notices and to communicate with them about Marketing Activities, which may include promotional information.
Users who are uncertain about which Personal Data is mandatory are welcome to contact Tooso at yourdata@tooso.ai.
If Users and Clients receive a marketing communication or promotion from Tooso via email, they may opt-out of these communications at any time by following the unsubscribe instructions included in the promotion.

5. Methods of processing

Tooso processes the Data in a proper manner and 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 this Privacy Policy.
In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (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 Data Controller.
Tooso may also disclose aggregated information about the Users and information that does not identify any individual, without restriction.

Place - The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Tooso at yourdata@tooso.ai.

Retention time - The Data will be retained in accordance with applicable legal provisions, for as long as necessary to fulfill the purposes for which they are processed. The criteria to determine the retention period of the Data take into account the allowed processing period and the applicable statute of limitations period and the nature of the legitimate interests where they constitute the legal basis of the process. Pursuant to the applicable legislation, the Personal Data could be retained for a longer period than that originally provided, in case of possible disputes or requests from the relevant authorities.
In any case, Tooso’s cookies expire after 1000 days of inactivity, to provide an optimal services also to the Clients of This Application that have infrequent, but high-value purchases across time (e.g. luxury goods).

6. Detailed information on the processing of Personal Data

Personal Data is collected and processed using the following services:

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 Application, 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 and Usage Data.
Place of processing: US.
For more details on Google’s Privacy Policy see we refer the User to:
https://www.google.it/analytics/terms/us.html

Contact forms on our Websites - By filling in the contact form with their Personal Data, the User authorizes This Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: company name, email address, first name, last name and phone number.

Interaction with external social network and platforms - This type of service allows interaction with social networks or other external platforms directly from the pages of This Application.
The interaction and information obtained through This Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Twitter’s Tweet button and social widgets (Twitter, Inc.) - The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy
For more details on Twitter’s Privacy Policy see we refer the User to:
https://twitter.com/it/privacy
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy
https://www.linkedin.com/legal/privacy-policy

7. Additional information and rights of Users

Legal actions - The processing of the Personal Data may also take place to manage possible disputes. Such possible processing could be carried out on the basis of a legitimate interest of the Data Controller, which intends to safeguard its interest and rights as acknowledged by the applicable laws.
Furthermore, the User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller 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 Application 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 Application and any third-party services may collect files that record interaction with This Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy - More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users - If you want to manage your preferences with reference to the usage of Tooso’s cookies within the context of our Services and our Websites, you may click here below and opt-out from This Application:

Switch

In any moment, the User will be entitled to:

Such rights may be exercised sending a communication via e-mail to: yourdata@tooso.ai

Without prejudice to any other administrative or jurisdictional appeal, the User has also the right to lodge a complaint with a supervisory Authority, where he/she deems that the processing of his/her data is carried out in violation of the GDPR. Further information are available on the website http://www.garanteprivacy.it.
Please contact the Data Controller before filing a complaint.

8. Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using This Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

9. Definitions and Legal References

Personal Data (or Data) - Any information regarding an identified or identifiable natural person.

Usage Data - Information collected automatically from This Application (or third-party services employed in This Application), which can include: the IP addresses or domain names of the computers utilized by the Users of This Application, 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. As for the services rendered by Tooso within third parties’ website, Usage Data include the data described in Section 2.

User - The individual using This Application, which must coincide with or be authorized by the data subject, to whom the Personal Data refers.

Data Processor - The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner) - The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of This Application. The Data Controller, unless otherwise specified, is the Owner of This Application.

This Application - The hardware or software tool by which the Personal Data of the User is collected. More precisely, This Application refers to the website www.tooso.ai and all websites within that domain (our Websites) and mobile applications and the Tooso services provided through Tooso’s cookies within third parties’ websites.

Cookies - Small piece of data stored in the User's device.

Legal information - Notice to European Users: this privacy statement has been prepared in fulfilment of the obligations under the EU Regulation 2016/679 of 27 April 2016, concerning the protection of individuals with regard to the processing of personal data as well as the free movement of such data (General Data Protection Regulation, hereinafter "GDPR").

This privacy policy relates solely to This Application.