Privacy Policy

Data Controller

The data controller is Ulturale s.r.l., in the person of its legal representative, domiciled at its registered office at Via San Clemente 1, 20122, Milan (MI)

Piva 03302470129


Types of Data Collected

Among the Personal Data collected by this Web Site, either independently or through third parties, are: email; password; Data disclosed during use of the service; Tracking Tool; Usage Data; first name; last name; various types of Data; billing data; Universal Unique Identifier (UUID); purchase history; device information; phone number; physical address; user subscriptions; IP address; pageview; device logs; operating systems; browsing history; browser information; clicks; interaction events; page scroll interactions; relative position to scroll; crash data.

Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such Data.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site is mandatory. If the User refuses to provide them, it may be impossible for this Web Site to provide the Service. In cases where this Web Site 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.
Any use of Cookies - or other tracking tools - by this Web Site or the owners of third party services used by this Web Site is for the purpose of providing the Service requested by the User, in addition to the additional purposes described herein and in the Cookie Policy.

The User assumes responsibility for third party Personal Data obtained, published or shared through this Web Site.


Method and place of processing of collected Data

Mode of treatment

The Owner takes 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, other subjects involved in the organization of this Web Site (administrative, sales, marketing, legal, system administrators personnel) or external subjects (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.



The Data are processed at the Holder's operational offices and at any other location 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 in which 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.


Retention period

Unless otherwise stated in this document, Personal Data is processed and kept for the time required by the purpose for which it was collected and may be kept for a longer period due to any legal obligations or based on Users' consent.

Purposes of the Processing of Collected Data

User Data is collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Contacting the User, Registration and authentication provided directly by this Website, Access to accounts on third-party services, Managing support and contact requests, Hosting and backend infrastructure, Remarketing and behavioral targeting, Traffic optimization and distribution, Statistics, Infrastructure monitoring, Payment management, Business affiliation, Transfer of Data outside the EU, Collection of privacy preferences, Interaction with live chat platforms, Management of User databases, Interaction with data collection platforms and other third parties, Registration and authentication, Management of web conferencing and online telephony, Tag management, Viewing content from external platforms, Contact management and messaging, Data linking, Advertising, Sale of goods and services online, Internal processing tools, Performance testing of content and functionality (A/B testing), and Creation and management of this Website.
To obtain detailed information about the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the "Personal Data Processing Details" section.

Facebook permissions required by this Web Site

This Web Site 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 Web Site to connect with the User's account on the social network Facebook, provided by Facebook Inc.
For more information on the following permits, please refer to the documentation of Facebook permits and to the Facebook privacy policy.
The required permits are as follows:

Background 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.



Provides access to the User's primary email address.


device information

Tracking Tools

Tracking Tool means any technology - e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows tracking Users, for example, by collecting or storing information on the User's device.


Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services: 
  • Access to accounts on third-party services
  • Data link
  • Creation and management of this Web site
  • User Database Management
  • Tag management
  • Web conferencing and online telephony management
  • Interaction with live chat platforms
  • Infrastructure monitoring
  • Advertisement
  • Registration and authentication
  • Remarketing and behavioral targeting
  • Commercial affiliation
  • Contact user
  • Managing contacts and sending messages
  • Payment management
  • Support request management and contact
  • Hosting and backend infrastructure
  • Interaction with data collection platforms and other third parties
  • Traffic optimization and distribution
  • Collection of privacy-related preferences
  • Registration and authentication provided directly from this website

Information on how to turn off interest-based advertisements

In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to turn off interest-based advertisements in the appropriate section of the Cookie Policy.

Cookie Policy

This Web Site makes use of Tracking Tools. To learn more, Users can consult the Cookie Policy.

More information for users

Legal basis for processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data 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;
  • processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
  • processing is necessary to fulfill a legal obligation to which the Controller is subject;
  • the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
  • 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.

Additional information on shelf life

Unless otherwise stated in this document, Personal Data is processed and kept for the time required by the purpose for which it was collected and may be kept for a longer period due to any legal obligations or based on Users' consent.


  • 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 attributable 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 Controller may retain Personal Data longer until that 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.

User Rights

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

In particular, to the extent provided by law, the User has the right to:

  • revoke consent at any time.The User may revoke consent to the processing of his or her Personal Data previously given.
  • object to the processingof your Data.You may object to the processing of your Data when it is done pursuant to a legal basis other than consent.
  • access your Data.You have 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.Users may verify the accuracy of their Data and request that it be updated or corrected.
  • obtain restrictionof processing.You may request restriction of the processing of your 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.Users may request the deletion of their Data from the Data Controller.
  • receive their Data or have it transferred to another owner.You have the right to receive your Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred unimpeded to another owner.
  • Proposea complaint.The User may propose a complaint to the relevant data protection supervisory authority or take legal action.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad including to any international organization governed by international law or formed by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect their Data.

Details of 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 are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reasons. If Users object to processing for direct marketing purposes, Personal Data are no longer processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. The request may be filed free of charge and the Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, deletion or restriction of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller shall notify the User of such recipients if the User so requests.

Transfer of personal data outside the European Union

Transfer of Data to countries that guarantee European standards

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 deems 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.

Transfer to third countries on the basis of standard contractual clauses

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 EU law. Users may request further information by contacting the Data Controller at the contact details indicated in this document.