Legal
Elsinor Privacy Policy
This notice describes how Elsinor S.R.L. processes Personal Data through www.elsinor.it, its own mobile applications and the services for which Elsinor acts as Data Controller (the “Services”).
This information applies to the features and processing activities actually present in the Service used. Any specific notices available within a Service supplement this policy. For applications developed by Elsinor on behalf of clients acting as Data Controllers, please refer to the relevant Controller’s privacy notice.
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Data Controller
Elsinor S.R.L.
Registered Office: Via Margifaraci 60, 90135 Palermo (PA)
Email: [email protected]
Types of Data Collected
Depending on the Service used, the Data processed may include contact details provided by the User (such as name, email and phone number), support request content, usage data, IP address and technical device information. Any advertising and in-app purchase data for Elsinor mobile applications are described in the dedicated section.
Data may be provided by the User or collected automatically while using the Services, including through integrated third-party providers. Data required for a feature is distinguished from optional data at the point of collection: withholding required data may prevent use of that feature.
Users sharing third parties’ Personal Data through the Services must be authorised to do so.
Methods and Place of Data Processing
Methods of Processing
Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Place
Data is processed at the Controller’s operating offices and in any other places where the parties involved in the processing are located. Personal Data may be transferred to a country other than the one the User is located in.
Retention Period
Data is processed and stored for as long as required by the purpose it has been collected for or to comply with legal obligations. Public-site access logs containing the date and time, entry page, and masked IP address are deleted after 30 days; aggregate daily counts are stored separately. Once the retention period expires, the Data will be deleted.
Purposes of Data Collection
Data is processed to provide and manage the Services used, respond to requests, comply with legal obligations and protect the security and rights of the Controller and Users. In particular:
- Contacting the User (contact form, phone, newsletter)
- Aggregate counting of public-site visits and review of entry logs with masked IP addresses
- Creating, managing and maintaining the Elsinor website and applications
- Managing contacts and sending messages (e.g. Mailchimp, HubSpot, mailcow)
- Managing user databases
- For the website: Tag management (e.g. Google Tag Manager)
- For the website: Heat mapping and session recording (e.g. Microsoft Clarity)
- For the website: Spam and bot protection (e.g. Google reCAPTCHA)
- For the website: Behavioral advertising and retargeting (e.g. Google Ads, Meta Pixel)
- For the website: Analytics (e.g. Google Analytics, HubSpot, Meta Events Manager)
- For the website: Displaying content from external platforms (e.g. Google Fonts)
- Displaying and measuring ads through Google AdMob in Elsinor mobile applications that integrate it, subject to applicable consent preferences
- Managing, verifying and restoring purchases in Elsinor mobile applications that offer in-app purchases
Legal Basis for Processing
The Controller may process Personal Data if one of the following conditions applies:
- Consent for purposes that require it, such as personalised advertising and access to device identifiers or information that is not strictly necessary. Consent may be withdrawn without affecting the lawfulness of earlier processing
- Performance of a contract or pre-contractual measures to deliver requested Services, manage in-app purchases and provide related support
- Processing is necessary to comply with a legal obligation
- Legitimate interests in securing the Services, preventing fraud and abuse and defending the Controller’s rights, subject to Users’ rights and freedoms
Elsinor mobile applications
Advertising through Google AdMob
Elsinor mobile applications that display ads through Google AdMob use its SDK, which collects and shares with Google data such as IP address (which may be used to estimate approximate location), app and ad interactions, diagnostic information and device identifiers, depending on configuration and applicable choices. Purposes include ad delivery and measurement and fraud prevention.
Advertising preferences
Ad personalisation and access to device information that require consent are subject to the User’s consent. Users must be able to change or withdraw their preferences through the app’s privacy controls. The advertising identifier can also be managed in device settings. Refusing personalisation does not necessarily prevent ads from being displayed or technical processing permitted by law.
In-app purchases
Elsinor mobile applications may offer in-app purchases through the store for the platform used. The following information applies to apps that include this feature. The store handles payment under its own privacy notice. To verify purchases, unlock content or restore it, the app may process transaction identifiers, receipts or purchase tokens, the purchased product and purchase status. Users do not need to provide Elsinor with their full card number or payment credentials.
Device permissions
Any permissions required by a specific feature are presented in context and can be managed in device settings. Refusing a permission may make the related feature unavailable. System permissions do not replace privacy consent where required.
Retention and deletion
Purchase data is retained for as long as needed to manage entitlements to purchased content, support and any legal obligations. Uninstalling the app does not automatically delete data already sent to Elsinor or its providers. To request deletion of data processed by Elsinor, email [email protected] specifying the app name or follow the dedicated procedure.
Privacy notices and requests
User Rights (GDPR)
- Withdraw consent
- Object to processing
- Access their Data
- Request rectification or update
- Request restriction of processing
- Obtain deletion of Data
- Receive Data in portable format (data portability)
- Lodge a complaint with the competent authority
Send requests to [email protected], specifying the Service concerned. We will respond within one month; for complex or numerous requests, this may be extended by a further two months, with reasons provided within the first month. You may lodge a complaint with the Italian Data Protection Authority or the competent supervisory authority.
Additional Information About Processing
- Legal defense: Data may be used in court or in the stages leading to possible legal action
- System logs and maintenance: may be collected for operational purposes
- Specific information: additional details may be provided upon request
- Changes to this privacy policy: the Controller reserves the right to modify it at any time