This Application collects some Personal Data of its Users.

Data Controller

Company name: Sigma Traiding 21 Ltd

Types of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, are: email, first name, last name, Cookie, Usage Data, phone number, profession, province, country, zip code, date of birth, city, address, company name, website, various types of Data, gender, VAT number, Tax Code, business sector, User ID, geographic location, image, About Me, Data disclosed while using the service, username, Room Permission, and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).

Other Personal Data collected may be indicated in other sections of this privacy policy or through informational text displayed at the same time as the Data is collected.

Full details on each type of Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of that Data.

Personal Data may be entered voluntarily by the User, or collected automatically during the use of this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.

Users in doubt about which Data are mandatory are encouraged to contact the Data Controller.

The possible use of Cookies – or other tracking tools – by this Application or the owners of third party services used by this Application, where not otherwise specified, is for the purpose of identifying the User and recording their preferences for purposes strictly related to the provision of the service requested by the User.

Failure by the User to provide certain Personal Data may prevent this Application from providing its services.

The User assumes responsibility for the Personal Data of third parties published or shared through this Application and warrants that he/she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

Mode and place of processing of collected Data
Modes of processing

The Data Controller processes Users’ Personal Data by taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, categories of appointees involved in the organization of the site (administrative, sales, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data related to the User in case one of the following conditions exists:

– the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

– the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;

– the processing is necessary for the performance of a legal obligation to which the Controller is subject;

– processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;

– the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the operating offices of the Data Controller and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

The User’s Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data

Should any of the transfers just described take place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting it at the contact details given at the beginning.

Retention Period

Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.

Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority
At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Data collected

User Data is collected to enable the Data Controller to provide its Services, as well as for the following purposes: Accessing accounts on third-party services, Contacting the User, Contact management and sending messages, Payment management, Handling of support and contact requests, Hosting and backend infrastructure, Content commenting, Social features, Tag management, Statistics,

Interaction with social networks and external platforms,

Heat mapping and session logging,

Interaction with live chat platforms,

Interaction with support and feedback platforms, Location-based interactions, Permissions to access Personal Data on the User’s device, Protection from SPAM, Advertising, Registration and authentication, Remarketing and behavioral targeting, Content and feature performance testing (A/B testing), Transfer of Data outside the EU, and Viewing content from external platforms.

To obtain further detailed information on the purposes of processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Facebook permissions required by this Application

This Application may require certain Facebook permissions that allow it to perform actions with the User’s Facebook account and collect information, including Personal Data, from it. This service allows this Application to connect with the User’s account on the social network Facebook, provided by Facebook Inc.

For more information about the permissions below, please refer to the Facebook permissions documentation and Facebook’s privacy policy.

Basic Information

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and language of location and, in some cases Facebook “Friends”. If the User has made additional Data publicly available, the same will be available.

Details on the processing of Personal Data

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

Access to accounts on third-party services.

These types of services allow this Application to take Data from your accounts on third-party services and perform actions with them.

These services are not activated automatically, but require your express permission.

Content Commenting

Commenting services allow Users to make and publish their own comments regarding the content of this Application.

The Users, depending on the settings decided by the Owner, can also leave the comment anonymously. In case among the Personal Data released by the User is email, this may be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.

In the event that a comment service provided by third parties is installed, it is possible that, even in the event that Users do not use the comment service, it may collect traffic data related to the pages where the comment service is installed.

Contacting the User

Contact by phone (this Application)

Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Application, as well as to fulfill support requests.

Personal Data Collected: phone number.

Contact Form (this Application).

The User, by filling out the contact form with their Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.

Personal Data collected: zip code, city, tax code, last name, date of birth, email, User ID, address, country, name, phone number, VAT number, profession, province, company name, gender, business sector, website, and various types of Data.

Contact Management and Message Sending

This type of services allows you to manage a database of email contacts, telephone contacts or contacts of any other type used to communicate with the User.

These services may also allow for the collection of data related to the date and time of the User’s viewing of messages, as well as the User’s interaction with them, such as information about clicks on links embedded in messages.

Mailgun (Mailgun, Inc.)

Mailgun is an address management and email message delivery service provided by Mailgun, Inc.

Personal Data collected: last name, Cookie, date of birth, Usage Data, email, address, country, first name, phone number, occupation, gender, and various types of Data.

Place of processing: United States – Privacy Policy.

Hosting and backend infrastructure

These types of services have the function of hosting Data and files that allow this Application to function, enable its distribution, and provide a ready-to-use infrastructure to deliver specific functionality of this Application.

Some of these services operate through servers located geographically in different locations, making it difficult to determine the exact location where Personal Data is stored.

Google Cloud Storage (Google Ireland Limited)

Google Cloud Storage is a hosting service provided by Google Ireland Limited.

Personal Data collected: various types of Data as specified by the service’s privacy policy.

Place of processing: Ireland -Privacy Policy . Privacy Shield Adherent.

Interaction with live chat platforms.

This type of service allows the User to interact with live chat platforms, operated by third parties, directly from the pages of this Application. This allows the User to contact the support service of this Application or this Application to contact the User while he/she is browsing its pages.

In the event that a service for interaction with live chat platforms is installed, it is possible that, even if Users do not use the service, it will collect Usage Data related to the pages where it is installed. In addition, live chat conversations may be recorded.

Interaction with social networks and external platforms

This type of service allows for interactions with social networks, or other external platforms, directly from the pages of this Application.

The interactions and information acquired by this Application are in any case subject to the User’s privacy settings related to each social network.

In the event that a social network interaction service is installed, it is possible that, even if Users do not use the service, it may collect traffic data related to the pages where it is installed.

Facebook Like Button and Social Widgets (Facebook, Inc.).

The Facebook “Like” button and social widgets are Facebook social network interaction services provided by Facebook, Inc.

Personal Data Collected: Cookies and Usage Data.

Place of processing: United States -Privacy Policy . Privacy Shield Adherent.

Location-based interactions.
Non-Continuous Geolocation (this Application).

This Application may collect, use, and share Data related to the User’s geographic location in order to provide location-based services.

Most browsers and devices provide by default tools to deny geographic tracking. If the User has expressly authorized this option, this Application may receive information about the User’s actual geographic location.

Geographical tracking of the User occurs on a non-continuous basis, upon specific request of the User or when the User does not indicate in the appropriate field the place where he/she is and allows the Application to automatically detect the location.

Personal Data collected: geographical location.

SPAM Protection.

This type of services analyzes the traffic of this Application, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited).

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.

Use of reCAPTCHA is subject to Google’s privacy policy and terms of use.

Personal Data Collected: Cookies and Usage Data.

Place of processing: Ireland – Privacy Policy.Privacy Shield adherent.

Registration and Authentication

By registering or authenticating, the User allows the Application to identify him/her and give him/her access to dedicated services.

Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. If this occurs, this Application may access some Data stored by the third-party service used for registration or identification.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.

Flazio Stats

Flazio provides a statistics service that analyzes and displays personal data of users who visit websites.

Personal Data Collected: Cookies and Usage Data.

Place of processing: Ireland -Privacy Policy Opt Out. Privacy Shield Adherent.

Transfer of Data outside the EU.

The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all non-EU countries) only in accordance with a specific legal basis. Therefore, such Data transfers are performed in accordance with one of the legal bases described below

The User may request information from the Controller regarding the applicable legal basis concretely applicable to each individual service.

Transfer to third countries on the basis of standard contractual clauses (this Application)

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of standard Personal Data protection clauses adopted by the European Commission.

In such cases, the recipients of the Data have agreed to treat the Personal Data in accordance with the levels of protection provided by the legislation. Users may request further information by contacting the Data Controller at the contact details indicated in this document.

Transfer to third countries based on consent (this Application).

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place only when the User has expressly consented to such transfer after being informed about the risks due to the absence of an adequacy decision and the appropriate safeguards adopted

In such cases, the Data Controller informs Users and collects their consent through this Application.

Personal Data collected: various types of Data.

Transfer of Data to countries that guarantee European standards (this Application).

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision adopted by the European Commission. The European Commission adopts adequacy decisions with respect to individual third countries that it considers to ensure a level of protection of Personal Data comparable to that provided by European legislation on the protection of Personal Data. The User can view the updated list of adequacy decisions on the European Commission’s website.

Personal Data collected: various types of Data.

Transfer of Data from the EU and/or Switzerland to the United States on the basis of the Privacy Shield (this Application).

When this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the United States occurs on the basis of the EU-US or Switzerland-US Privacy Shield agreement.

In particular, Personal Data is transferred to entities that have self-certified under the Privacy Shield and thus ensure an adequate level of protection for the transferred Data. The services affected by the transfer of Data are listed in the respective sections of this document. Among them, those that adhere to the Privacy Shield can be identified by consulting the relevant privacy policy or by checking the status of their membership in the official Privacy Shield list.

Users’ rights under the Privacy Shield are described in continually updated form on the U.S. Department of Commerce website.

Transfer of Personal Data from the EU or Switzerland to the U.S. to entities not (any longer) enrolled in the Privacy Shield is permissible only under other valid legal basis. Users may request information from the Data Controller regarding such legal bases.

Personal Data collected: various types of Data.

Display of content from external platforms

This type of services allows to display content hosted on external platforms directly from the pages of this Application and interact with them.

In the event that a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data related to the pages where it is installed.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Application to integrate such content within its pages.

Personal Data collected: Usage Data and various types of Data as specified by the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield Adherent.

Google Maps Widget (Google Ireland Limited)

Google Maps is a map display service operated by Google Ireland Limited that allows this Application to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: Ireland -Privacy Policy Privacy Shield adherent.

User Data analysis and forecasting (“profiling”).

The Owner may process Usage Data collected through this Application to create or update user profiles. This type of processing allows the Owner to evaluate User choices, preferences and behavior for the purposes specified in the respective sections of this document.

User profiles may also be created through automated tools, such as algorithms, which may also be offered by third parties. To obtain further information on profiling activity, the User may refer to the respective sections of this document.
The User has the right to object to such profiling activity at any time. To find out more about the User’s rights and how to exercise them, the User may refer to the section of this document on Users’ Rights.

Personal Data collected through sources other than the User

The Owner of this Application may have lawfully collected Personal Data about the User without the User’s involvement, drawing on sources provided by third parties, in accordance with the legal bases described in the section on the legal bases for processing.

If the Controller has collected Personal Data in such a way, the User can find specific information regarding the sources in the respective sections of this document or by contacting the Controller.

Sale of goods and services online

The Personal Data collected is used for the provision of services to the User or the sale of products, including payment and possible delivery. The Personal Data collected to finalize the payment may be that related to the credit card, bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

-revoke consent at any time. Users may revoke their previously expressed consent to the processing of their Personal Data.

-oppose the processing of their Data. The User may object to the processing of his/her Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.

-access to one’s own Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the Data processed.

-verify and request rectification. The User may verify the correctness of its Data and request its update or correction.

-obtain the limitation of processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.

-obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.

-receive their Data or have it transferred to another Data Controller. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.

-Propose Complaint. The User may file a complaint with the competent data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users may refer to the respective sections of this document.

How to Exercise Rights

To exercise the User’s rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.

More information about Personal Data
Sale of goods and services online

The Personal Data collected is used for the provision of services to the User or the sale of products, including payment and possible delivery.

The Personal Data collected to finalize the payment may be that related to the credit card, bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used.

Additional information on processing

Defense in Court

The User’s Personal Data may be used for the defense by the Owner in court or in the preparatory stages of its possible establishment, from abuse in the use of the same or related services by the User.

The User declares that he/she is aware that the Data Controller may be required to disclose the Data at the request of public authorities.

Specific disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual disclosures regarding specific services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services used by it may collect System Logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact information.

Exercise of Rights by Users

The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or non-existence of the same at the Data Controller, to know its content and origin, to request a copy of all processed data, to verify its accuracy or request its integration, the deletion of the account and processed data, updating, rectification, transformation into anonymous form or blocking of Personal Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing. Requests should be addressed to the Data Controller.

For any request about the processing of your data on minercom.eu please write to us at info@minercapital.io. This Application does not support “Do Not Track” requests. To find out whether any third-party services used support them, please consult their privacy policies.

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 Users on this page. Therefore, please consult this page often, taking as reference the date of last modification indicated at the bottom. If you do not accept the changes made to this privacy policy, you must cease using this Application and may request the Data Controller to remove your Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected up to that point.

About this privacy policy

The Data Controller is responsible for this privacy policy, which was drafted from forms prepared by Iubenda and stored on its servers.

Definitions and legal references

Personal Data (or Data)

Personal Data is any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

This is the information collected automatically by this Application (or by the third party applications that this Application uses), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the User’s computer environment.

User

The individual who uses this Application, who must coincide with or be authorized by the Data Subject and whose Personal Data is the subject of the processing.

Data Subject

The natural or legal person to whom the Personal Data relate.

Data Processor (or Processor)

The natural person, legal entity, public administration and any other entity, association or body appointed by the Data Controller to process Personal Data, in accordance with the provisions of this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration and any other body, association or body responsible, even jointly with another owner, for decisions regarding the purposes, methods of processing of Personal Data and the tools used, including the security profile, in relation to 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 Users’ Personal Data are collected.

Cookie

Small portion of data stored within the User’s device.

Legal references

This Privacy Policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

This privacy policy covers this Application only.

Legal references

This privacy policy is prepared based on multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

This privacy policy covers this Application only.

Contact

If you have any questions regarding this Privacy Policy, please contact us at info@minercapital.io.

Date of last revision: 15/04/2022