Cookie Policy of summinar.com

This document informs Users about the technologies that help this Website to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Website.

For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

This Website uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.

To find more information dedicated to Californian consumers and their privacy rights, Users may read the privacy policy.

Activities strictly necessary for the operation of this Website and delivery of the Service

This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Third-party Trackers

  • Hosting and backend infrastructure

    This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.

    Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Akamai Content Delivery Network (Akamai Technologies, Inc.)

    Akamai is a hosting service provided by Akamai Technologies, Inc.

    Personal Data processed: Tracker and Usage Data.

    Legal basis for processing: Legitimate interest.

    Place of processing: United States – Privacy Policy.

    Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.

    Data retention period: 6 months.

  • Infrastructure monitoring

    This type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.

    New Relic (New Relic)

    New Relic is a monitoring service provided by New Relic Inc.
    The way New Relic is integrated means that it filters all traffic of this Website, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Website to be collected.

    Personal Data processed: Tracker, Usage Data and various types of Data as specified in the privacy policy of the service.

    Legal basis for processing: Legitimate interest.

    Place of processing: United States – Privacy Policy.

    Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.

    Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.

  • Handling payments

    Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

    PayPal (PayPal Inc.)

    PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

    Personal Data processed: Tracker and various types of Data as specified in the privacy policy of the service.

    Place of processing: See the PayPal privacy policy – Privacy Policy.

    Legal basis for Data transfer outside the EU: Binding corporate rules.

    Data retention period: Keeping the data as long as required by relevant national law.

    Braintree (PayPal (Europe) S.a.r.l. et Cie, S.C.A.)

    Braintree is a payment service provided by Braintree, a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.

    Personal Data processed: Tracker and various types of Data as specified in the privacy policy of the service.

    Legal basis for processing: Consent.

    Place of processing: See the Braintree privacy policy – Privacy Policy.

    Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.

    Data retention period: Keeping the data as long as required by relevant national law.

Other activities involving the use of Trackers

Basic interactions & functionalities

This Website uses Trackers to enable basic interactions and functionalities, allowing Users to access selected features of the Service and facilitating the User's communication with the Owner.

Experience enhancement

This Website uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.

Measurement

This Website uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.

Targeting & Advertising

This Website uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.

How to manage preferences and provide or withdraw consent

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:

Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.

It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.

Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

Locating Tracker Settings

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).

How to opt out of interest-based advertising

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Owner and Data Controller

Summinar Limited
167-169 Great Portland Street, 5th Floor, London, W1W 5PF

Owner contact email: [email protected]

Since the use of third-party Trackers through this Website cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Website.

Definitions and legal 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.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on 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).

This privacy policy relates solely to this Website, if not stated otherwise within this document.