Filobot (hereinafter "Filo") collects some Personal Data from its Users.
Email for communications regarding Data Protection: [email protected]
Types of Data collected
Among the types of Personal Data that Filo collects, by itself or through third parties, there are: Tracker; Usage Data; Username; Server.
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 Filo.
Unless specified otherwise, all Data requested by Filo is mandatory and failure to provide this Data may make it impossible for Filo to provide its services. In cases where Filo 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 Filo or by the owners of third-party services used by Filo 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 Cookies Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Filo.
Mode and place of processing the 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 Filo (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:
- When the Users have given their consent for one or more specific purposes. Notice: Under various different legislations, the Holder may be authorized to process Personal Data until the User objects to it ("non-participation option"), without the need for consent or any other legal basis. However, this will not be applicable when the processing of Personal Data is subject to European regulations on the protection of Personal Data.
- When obtaining Data is necessary for the fulfillment of a contract between the User and/or any other pre-contractual obligation thereof.
- When the treatment is necessary for the fulfillment of a legal obligation of obligatory fulfillment on the part of the User.
- When the treatment is related to a task carried out in the public interest or in the exercise of official powers granted to the Holder.
- When the treatment is necessary for the purpose of a legitimate interest pursued by the Owner or a third party.
In any case, the Owner is at your disposal to define the specific legal bases that apply to the treatment and in particular, if the obtaining of Personal Data is a contractual or statutory requirement or a necessary requirement to formalize a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Owner.
Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Owner suspend or remove the data.
The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Hosting and backend infrastructure, Registration and authentication, Advertising, Displaying content from external platforms, Infrastructure monitoring, Interaction with external social networks and platforms, Remarketing and behavioral targeting, SPAM protection, Tag Management and Traffic optimization and distribution.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
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 Filo, 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 Filo. 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 the Network Advertising Initiative opt-out page.
Google AdSense (Google Inc.)
Google AdSense is an advertising service provided by Google Inc. This service uses the "Doubleclick" Cookies, which tracks use of Filo and User behavior concerning ads, products and services offered.
Users may decide to disable all the Doubleclick Cookies by clicking on: myadcenter.google.com/controls.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager (Google Inc.)
Google Ad Manager is an advertising service provided by Google Inc. that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Your Online Choices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the "DoubleClick" Cookies, which tracks use of Filo and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by clicking on: myadcenter.google.com/controls.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
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 Filo.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
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 Filo, 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: United States – Privacy Policy – Opt Out.
Chat support
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Filo, for contacting and being contacted by Filo support service.
Chatwoot (Chatwoot Inc.)
Chatwoot is a chat support service provided by Chatwoot Inc.
- Personal Data collected: Cookies; Data communicated while using the service; Usage Data.
- Place of processing: United States – Privacy Policy.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Filo and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Statuspage widget (Atlassian Pty Ltd)
Statuspage widget is a content visualization service provided by Atlassian Pty Ltd that allows Filo to incorporate content of this kind on its pages.
- Personal Data collected: Tracker and Usage Data.
- Place of processing: United States – Privacy Policy.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Filo to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Filo. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
GalaxyGate (GalaxyGate LLC)
GalaxyGate is a hosting and backend service provided by GalaxyGate.
- Personal Data collected: various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Google Cloud Platform (Google Inc.)
Google Cloud Platform is a hosting and backend service provided by Google Inc.
- Personal Data collected: various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Oracle Cloud (Oracle Corporation)
Oracle Cloud is a hosting and backend service provided by Oracle Corporation.
- Personal Data collected: various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Infrastructure monitoring
This type of service allows Filo 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 Filo.
Sentry (Functional Software Inc.)
Sentry is a monitoring service provided by Functional Software Inc.
- Personal Data collected: Tracker and Usage Data.
- Place of processing: United States – Privacy Policy.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Filo.
The interaction and information obtained through Filo 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.
It is recommended to log out from the respective services in order to make sure that the processed data on Filo isn't being connected back to the User's profile.
Discord button and social widgets (Discord Inc.)
The Discord button and social widgets are services allowing interaction with the Discord social network provided by Discord Inc.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy.
Registration and authentication
By registering or authenticating, Users allow Filo to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Filo will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Discord Authentication (Discord Inc.)
Discord Authentication is a registration and authentication service provided by Discord Inc. and is connected to the Discord network.
- Personal Data collected: various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Remarketing and behavioral targeting
This type of service allows Filo and its partners to inform, optimize and serve advertising based on past use of Filo 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.
Google Ads Remarketing (Google Inc.)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of Filo with the Google Ads advertising network and the DoubleClick Cookies.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics Remarketing (Google Inc.)
Google Analytics Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookies.
- Personal Data collected: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
SPAM protection
This type of service analyzes the traffic of Filo, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Turnstile (Cloudflare Inc.)
Turnstile is a SPAM protection service provided by Cloudflare Inc.
- Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Filo 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: Cookies and Usage Data.
- Place of processing: United States – Privacy Policy – Opt Out.
Traffic optimization and distribution
This type of service allows Filo to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Filo and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Filo, i.e., communication between Filo and the User's browser, while also allowing analytical data from Filo to be collected.
- Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service.
- Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookies Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the "GDPR"), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled Detailed information on the processing of Personal Data within this document.
Legal basis for 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.
- 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.
Further information about 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.
The rights of Users based on the General Data Protection Regulation (GDPR)
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.
- 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.
- 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 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 to obtain the erasure of their Data from the Owner.
- 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.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including 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.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
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.
Additional information about Data collection and processing
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 Filo 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, Filo 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, Filo and any third-party services may collect files that record interaction with Filo (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.
How "Do Not Track" requests are handled
Filo does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.
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 Filo 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 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 Filo (or third-party services employed in Filo), which can include: the IP addresses or domain names of the computers utilized by the Users who use Filo, 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 Filo 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 Filo. The Data Controller, unless otherwise specified, is the Owner of Filo.
Filo (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Filo 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).
This privacy policy relates solely to Filo, if not stated otherwise within this document.
