Privacy Policy

Personal Data

The Personal Data and Browser Data (hereinafter collectively referred to as “Data”), automatically collected from this website (hereinafter the “Site”), by means of automated systems or freely entered by the User or the Interested Party, are collected for the purposes, and processed, as follows below.

Parties processing the data

Owner of the Data Processing System

Boalt Holdings, LLC
1395 Brickell Avenue
Suite 800
Miami, FL, 33131
305-514-0159
privacy@boalt.com


 

Kinds of Data

The Data that may be collected by this Site are name, surname, address, phone number, email, fax, social security number, IP address and other Data relating to the User’s identity or technical access to the Site by the User. When Sensitive Personal Data are transferred (personal data revealing racial or ethnic, religious, philosophical or other beliefs, political opinions, membership of political parties, trade unions, associations or organizations of a religious, philosophical or political nature, and personal data disclosing information about health and sex life), it may be necessary to obtain consent in order to process them.

The Browser Data referring to the technical use of the Site must be collected, and transfer is not optional. The User may freely provide the remaining Data, including personal information, unless it is expressly indicated otherwise.

Failure to process certain Data (e.g. contact details, or addresses, or data concerning behavior or user preferences, etc.) may make it impossible for the Site to provide its services.

If the User utilizes the Site to publish or otherwise share Personal Data with third parties, he or she assumes full responsibility: the User states possession of the right to communicate or disclose personal data to third parties, and that they have received prior information thereto, thus relieving the Site of all responsibility for their improper use following disclosure or dissemination.


 

Mode and place of processing of the information obtained

Method of Processing

The Data Controller processes the Data of the Interested Parties and Users in a lawful and proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data. Processing is carried out using computers and / or telematic means, with organizational methods and logics strictly related to the stated purposes. In addition to the owner, in some cases, access to the Data may be available to personnel involved in the organization of the Site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, mail carriers , hosting providers, IT companies, communications agencies) appointed, if necessary, as Managers by the Owner of the Processing procedure. The updated list of Managers can be requested from the Owner by contacting the above address at any time.

Place

The Data are processed at the headquarters of the Data Controller. Any processing of Data outside one of the EU Member States may require the consent of the User or the Interested Party.

Time

The Data are kept for the time necessary to perform the service requested by the User, and the User can always ask for removal from the servers of the Site for legitimate reasons.


 

The use of the collected Data

The provision of the service or delivery of goods for sale purchased on the Site, and more generally, for administrative and accounting or technical purposes;

  • The Provision Of The Service;
  • a response to specific requests for information by the User;
  • a User update on new products or services provided by the Site or concerning particular business offers;
  • the User to be informed of any Site maintenance or inconvenience;
  • any commercial profiling of the User;
  • to display banners related to User interests (behavioral targeting / advertising);
  • defense by the Website Owner, in court or in the stages leading to possible legal action, against improper use of the same or related services by the User.

Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geolocation, etc.) may require the express consent of the User or the Interested Party.

Specific information may be shown on the pages of the Site in connection with particular services or processing of Data provided by the User or by the Interested Party.


 

Services provided by this website

The use of Data for additional purposes by the Data Controller, or for services for which it is necessary to collaborate with third parties, listed below, may in some cases require the free and specific consent of the User or the Interested Party.

Mailing List / Newsletter

Mailing List / Newsletter (This Website)

Following registration to the mailing list / newsletter, the User’s e-mail address is automatically added to the contact list of recipients of the newsletter and information of a commercial or promotional nature concerning the Website.

The personal data collected are: Email, First Name, Last Name and IP.


 

Purpose of the information collected and Services utilized on the website

The purpose of the treatment of the personal information, the personal information collected and any suppliers of third party services involved are mentioned hereinafter.

Comment services

The Comment services allow Users to formulate and share their views on the content of the Site.

Disqus (Disqus)

Disqus is a service that allows the display and exchange of Users’ comments on this Site. The Personal Data are collected by Big Heads Labs Inc, USA, a company that adheres to the Safe Harbor Privacy Policy Framework and ensures European safety standards. Personal Data are collected using permanent cookies, session cookies, or provided voluntarily by the User. The Personal Data collected are used to give notice to the User of the comments left on the Website and to provide, directly or indirectly, commercial information, including sending out newsletters. The User is solely liable for the information provided in the discussion windows and no liability is assumed for the use of such information by third parties.

Place of Data Processing: USA
More information: http://docs.disqus.com/help/30/

The personal data collected are: Cookie and IP.

The services contained in this section, provided by third parties, are used to track User behavior and, in case of profiling, they can require the User’s express consent.

Analytics

Google Analytics (Google)

Google Analytics is a web analysis service supplied by Google, Inc. (“Google”), which uses “cookies” to collect Users’ Personal Data which are forwarded to, and deposited on, Google’s servers in the United States. Google uses the Data collected to (i) track and examine the Website’s usage, (ii) prepare reports on the Website’s activities for the website managers and (iii) supply other optional services. Google may use the Data collected to carry out behavioral targeting of the Website’s Users. Google does not associate the user’s IP address with any other information in Google’s possession. Any refusal to utilize the cookies, by selecting the appropriate setup on your browser, may prevent the use of some functions of this Website.

Place of Data Processing: USA
More information: http://www.google.com/intl/en/analytics/privacyoverview.html

The personal data collected are: Cookie and IP.

Optimizely (Optimizely)

Optimizely is a statistical service provided by Optimazely inc. that makes it possible to keep a record and analyze the response, in terms of the traffic of website users in relation to amendments in the layout of the Website and modification of its services. User data are acquired and processed in the USA for statistical purposes.

Place of Data Processing: USA
More information: http://www.optimizely.com/privacy

The personal data collected are: Cookie and IP.

KISSmetrics (KISSmetrics)

KISSmetrics is a data analysis service, supplied by Kissmetrics Inc., that aggregates several items of Data (purchases made, pages viewed, use of the web site) with other information otherwise supplied by the User (e.g. e-mail address) to track the User’s behavior on the Website. The User, by using the services offered by this Website, expressly agrees to the forwarding and treatment of his/her/its Data in the United States.

Place of Data Processing: USA
More information: http://www.kissmetrics.com/terms

The personal data collected are: Cookie and IP.

Email management

These services, provided by third parties, allow the Site to manage and monitor lists of the email addresses of their Users and communicate with them via email.

Mailchimp (Mailchimp)

Mailchimp is a mailing list service supplied by Mailchimp Inc., which makes possible to manage a contacts database in order to send e-mails connected to the services offered by the Website. The service allows the Data Controller to collect information about the date and time when the e-mails are visualized by the User, as well as information about User’s clicks on the addresses contained in the e-mail sent.

Place of Data Processing: USA
More information: http://www.mailchimp.com/legal/privacy/

The personal data collected are: First Name, Last Name, Email.


 

The Rights of Interested Parties

Those persons to whom the Data refer, have the right, at any time, to obtain confirmation of the existence or otherwise of information by consulting the Data Controller, to learn about their contents and origin, to verify their accuracy or to ask for their integration, cancellation, update or correction, their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Processor at the address cited in the “Data Controller” section.


 

Information about this privacy policy

Legal information

This privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of cookies.

This privacy statement applies solely to the Site and is not meant to refer to other sites whose links are possibly contained therein.

Latest update: April 04, 2012


 

Definitions and legal references

Personal information

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Browsing Details
Details collected automatically from the site, including the IP addresses or domain names of the computers utilized by the users who connect to the site, 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 obtained in reply, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of provenance, the features of the browser and the operating system utilized by the visitor, the various time details per visit (for instance the time spent on each page) and the details about the path followed within the site with special reference to the sequence of pages visited, other parameters about the operating system and the user’s IT environment.

User
Means the individual user of the Site’s services or products.

Interested Party
Indicates the subject to which the Personal Data refers, using the services or the products of the site.

Data Processor
The natural person, legal person, public administration or any other organization, association or organization designated by the Data Controller for the Personal Data processing system.

Data Controller
The natural person, legal person, public administration or any other organization, 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 Site.

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Terms of Use Company