Owner and Data Controller
The Smarter Crew, Via VM 11, 08018, Sindia, Italy
VAT number 01569660911
Owner contact email: info@thesmartercrew.com

1. WHO WE ARE
The Smarter Crew by Ileana Vidili (“The Smarter Crew”, “Company,” “we,” or “us”) respects your privacy and is committed to protecting it through this Privacy Policy. This Privacy Policy governs your access to and use of www.ileniavidili.com including any content, functionality and services offered on or through www.ileniavidili.com (the “Website“), whether as a guest or as a customer.
For the purposes of data protection law, The Smarter Crew by Ileana Vidili is the controller of the personal information it collects from you. This means that it decides why and how your personal information is processed and is responsible for that processing.

When accessing this Website, the Company will learn certain information about you, both automatically and through voluntary actions you may take, during your visit. This policy applies to information we collect on the Website and in email, text, or other electronic messages between you and the Website.
Please read the Privacy Policy carefully before you start to use the website and its services. By using the Website or by clicking to accept or agree to the Terms of Use when this option is made available to you, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Website and its services.

2. TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU
This website collects personal information from you if you (or an organisation for whom you work) purchase or use our services, request information, register for an event, sign up to an e-alert service or correspond with us. We collect and process the following personal information about you:
– Identity information, such as your first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
– Contact information, such as email address.
– Technical information, such as internet protocol (IP) address, your login data, browser type and version, location, operating system and platform and device and cookie IDs on the devices you use to access this website and our other web-based products.
– Profile information, such as feedback and survey responses.
– Usage information, such as information about how you use our website, products and services. Our technologies automatically collect and log certain information to help us administer, protect, and improve our services, analyse usage and improve user experience.
– Marketing and communications information, such as your preferences in receiving marketing from us and, where applicable, third parties and your communication preferences.
– Other information relating to you which you may provide to us, for example in the correspondence that you send to us.

3. USE OF COOKIES AND PIXELS
Similar to other websites, our website utilises a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.

– Third party use of cookies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. HOW DO WE USE YOUR PERSONAL INFORMATION?
4.1. Direct contact with you during the course of business. You may give us your contact details, payment details for invoice purposes, at events or by corresponding with us by post, phone, email or in other ways (all of which are provided by you on voluntary basis). This includes personal information you provide when you:

– subscribe to our products or publications
– request marketing information to be sent to you
– respond to our surveys
– provide us with some feedback on our products or services
– provide us with your contact details for us to assist you with using our products
– interact with us at events and meetings

If you do not provide this information, you will not be able to interact or communicate with us or our services in the ways mentioned above.

4.2. Email information
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site.

4.3. Personalisation
We use your personal information to deliver and suggest tailored content to personalise your experience with our services and websites. From time to time we may tailor and personalise marketing communications that we send to you, for example, by notifying you of products, services, offers or promotions that apply to your interests, location, industry sector, employer or job role.

4.4. Marketing and events
We use your personal information to deliver marketing and event communications to you across various platforms, such as email and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference for our services for you to manage your information and marketing preferences. If you do not wish to receive marketing communications from us, you can opt-out at any time by using the unsubscribe link inside the email (to unsubscribe from marketing emails) or by sending an email to info@thesmartercrew.com

5.HOW AND WHY WE COLLECT INFORMATION
The Company collects your information in order to record and support your participation in the activities you select. If you register to download a book or resources, sign up for our newsletter, and/or purchase a product or service from us, we collect your information. We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services. As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download resources and/or register for services that you are required to provide information.

If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will automatically enroll you to receive our free email newsletter. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to info@thesmartercrew.com requesting to unsubscribe from future emails.

If you are in the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will only enroll you to receive our free email newsletter if you affirmatively consent to it. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to info@thesmartercrew.com requesting to unsubscribe from future emails.

6. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
The Smarter Crew only shares or discloses personal information when necessary to provide its services or conduct our business operations as described below. When we share personal information, we do so in accordance with our documented data privacy and security requirements. Below are the parties with whom we may share your personal information and the reasons that we share that information.

– Our suppliers, service providers and other recipients

We may share your information with our third party service providers, agents, subcontractors and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf.

– Recipient / relationship to us
– Industry sector (& sub-sector)
– Accountancy services
– Professional services (accountancy)
– Advertising/digital agencies
– Marketing (advertising and digital)
– Banks, payment processors and financial services providers
– Financial (banking)
– Cloud storage providers
– IT (cloud services)
– Direct marketing service providers
– Marketing (direct marketing)
– Financial auditing services
– Audit (financial)
– Government tax administration offices
– Government (tax)
– IT support service providers
– IT (support and maintenance)
– Legal advisers
– Professional services (legal services)
– On-site security access control services
– Security (on-site)

The recipients mentioned above are located in the European Economic Area.

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.

When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organisations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.

7. HOW DO WE PROTECT YOUR INFORMATION AND SECURE INFORMATION TRANSMISSIONS?
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors.

Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.
For site security purposes and to ensure that this service remains available to all users, the Company uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.

8. POLICY CHANGES
We may use your contact information to inform you of changes to the Website or its Content, or, if requested, to send you additional information about us. We reserve the right, at our sole discretion, to change, modify or otherwise alter our Website, its Content and this Privacy Policy at any time. Such changes and/or modifications shall become effective immediately upon posting our updated Privacy Policy. Please review this Privacy Policy periodically. Continued use of any of information obtained through or on the Website or its Content following the posting of changes and/or modifications constitutes acceptance of the revised Privacy Policy.

9. YOUR RIGHT REGARDING YOUR PERSONAL INFORMATION
The European Union’s General Data Protection Regulation and other applicable data protection laws provide you with rights over your personal information.
The Smarter Crew respects your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. Please remember, that on occasions your personal information may have been shared with you by your employer or by other organisations, such as educational institutions, to which you belong, if they use our services and products.

If you wish to exercise any of your rights listed below, please contact us by email at info@thesmartercrew.com. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.

– Information regarding processing: You have the right to be informed about why, how and by whom your personal information is processed (which is what this policy sets out to do).

– Access to personal information: If you request access to a copy the personal information we hold about you, we will gladly comply, subject to any relevant legal requirements and exemptions, including completing our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
Request correction: You have the right to correct or amend your personal information if it is inaccurate or requires updating.

– Request deletion: You have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors.
Object to processing: If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect your choice in accordance with our legal obligations. In relation to Marketing preferences: You can opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable email preference centre. For other marketing preferences, you can use the “Contact Us” option within the relevant Service. Please see further Marketing & Events above. Please see also information related to controlling cookies, which is located in our Cookies Policy above.

– Restriction of processing: You can ask us to suspend the processing of your personal information if you want us to establish the accuracy of the information; where our use of the information is unlawful but you do not want us to erase it; where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; and you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

-Request personal information transfer (“data portability“): We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time: You have the right to withdraw your personal information where we are relying on consent to process it. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10.LINKS TO THIRD PARTY WEBSITES
The Website and social media pages contain links to third party websites that are not subject to this Privacy Policy. The Smarter Crew strongly recommends that you read the privacy policy of any such websites that you visit.

11.CONTACTS
The Smarter Crew by Ileana Vidili – info@thesmartercrew.com The Smarter Crew by Ileana Vidili is a company incorporated in Italy under the VAT number 01569660911