This Privacy Policy is made pursuant to Art. 13 of European Regulation no. 679/2016 and applies exclusively to all Data collected through the Website www.togoloco.com . This Privacy Policy is subject to updates that will be posted timely on the Website. This Privacy Policy and the

Cookie Policy

, establish the basis on which the User’s Personal Data will be processed.

Data Controller

The Data Controller of the Data collected by this Web Site is Stefania Ferraguti, based in Modena (MO), 41125, via Oristano n. 43, VAT 02405770369, Tax ID FRRSFN71H53F257F, email: info@togoloco.com

Methods of Processing Personal Data

The Personal Data provided or acquired will be subject to Processing based on the principles of fairness, lawfulness, transparency and protection of confidentiality in accordance with current regulations. The Data Controller processes Users’ Personal Data by taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. Processing is carried out by means of computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes.

Purpose of the Processing of Personal Data and Legal Basis

Personal Data may be collected independently by the Owner or through third parties. In this case, the computer systems and software procedures in charge of the operation of this Website acquire certain Personal Data of the Users, of a technical-informatics nature (e.g. IP address, type of browser used, operating system, domain name and addresses of websites from which access or exit was made, etc.), the transmission of which is inherent to the normal operation of the Internet. Such Data may be processed for the sole purpose of obtaining anonymous statistical information on the use of the site and/or to check its correct functioning and will be deleted immediately after processing.

The Data that the User voluntarily chooses to provide is collected to enable the Website to provide its services, as well as for the following Purposes:

a) to follow up on specific requests made to the Controller by the User for communications of an informational nature relating to the Services of the same Controller, via e-mail messages or filling out the Contact Form and other communication tools such as telephone or WhatsApp instant messaging. This processing is optional and based on the User’s consent, however, failure to provide one or more Data will result in the impossibility of responding to the request for information and enjoying the services offered by the Owner;

(b) for sending promotional and commercial information and offers sent by e-mail, mail or text message. This processing is based on the User’s freely expressed consent;

c) for sending through the newsletter service of promotional and commercial information and offers in order to stay updated on the activities carried out by the Holder. This processing is based on the User’s freely expressed consent;

d) to perform statistical analysis on aggregated and anonymous data to analyze the behaviors, of the User to improve the products and services provided by the Owner as well as meet the User’s expectations;

(e) for profiling activities for marketing purposes. This Processing is based on the User’s freely expressed consent.

(f) to fulfill any kind of obligation contemplated and provided for by applicable laws, regulations, related rules, business customs, and tax/fiscal matters. This processing is mandatory to fulfill a legal obligation to which the Data Controller is subject;

g) for other purposes ancillary or related to those indicated above and otherwise within the scope of the Website’s activities.

Category of Personal Data Processed

Among the Personal Data processed by this Website, either independently or through third parties, are Common Data such as: Cookie, Usage Data, first name, last name, email, phone, province. The optional, explicit and voluntary sending of electronic mail through the Contact Form or by means of the addresses indicated on this Web Site involves the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other Personal Data included in the email.

Disclosure of Data

In addition to the Owner, in some cases, they may have access to the Data:

(a) categories of specially trained appointees involved in the organization of the Website (administrative, sales, marketing, legal, system administrators);

b) external parties (such as third party technical service providers, hosting providers, IT companies, communication agencies) also appointed as Data Processors by the Data Controller ex art. 28 GDPR. An up-to-date list of Data Processors, if appointed, can always be obtained from the Data Controller;

c) public or private entities that can access the Data in compliance with legal obligations;

d) individuals who perform tasks that are ancillary and instrumental to the Holder’s business;

Timing of Treatment

As expressly stipulated in Art. 5, co. 1, lett. e) of the GDPR, the Data are kept for the time necessary for the Processing of the same in relation to the performance of the service requested by the User, or required by the Purposes described in this document and in particular:

– Data collected for contractual obligations will be kept for as long as necessary to fulfill the above purposes and as required by law;

– Data collected for tax/administrative or contractual obligations will be kept for as long as necessary to fulfill the above purposes and as required by law;

– Data collected for Purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied; You may obtain further information regarding the legitimate interest pursued by the Data Controller by contacting the Data Controller.

– Data collected based on User Consent may be retained until such Consent is revoked;

Data may be retained by the Data Controller for a longer period in compliance with legal obligations or by order of an authority.

At the end of the retention period, Personal Data will be deleted and therefore, the rights of access, deletion, rectification, and portability of Data can no longer be exercised

Cookie

This Website uses cookies. Cookies are small text files that can be used by websites to make the experience more efficient for the user and to personalize content and ads, provide social network features, and analyze traffic. Cookie Policy

Place of Processing and Transfer of Data Abroad

The Data are processed at the Holder’s operational headquarters. For more information you may contact the Data Controller. Data may be processed by individuals and/or legal entities operating on behalf of the Data Controller and under specific contractual obligations and based in EU or non-EU member countries. In the event that Data is transferred outside the EEA, the Data Controller will take all appropriate contractual measures to ensure adequate protection of the Data.

Tools used for the Processing of Personal Data

CONTACT FORM

By filling out the Contact Form with your Data, you consent to their use to respond to requests for information, or any other purpose indicated by the header of the form. Personal Data Collected through Contact Form: Email, First Name and Last Name, Phone.

Elementor (Elementor Ltd)

Elementor provides a Form creation and management service that allows this website to integrate such content within its pages. Personal Data Collected: Email, Phone, First Name, and Last Name. Various types of Data as specified by the Privacy of Service. Place of Processing: ISRAEL –
Privacy Policy

Contact Form 7 (Rock Lobster LLC)

is a Form creation and management service that allows this website to integrate such content within its pages. Personal Data Collected: Email, Phone, First Name, and Last Name. Various types of Data as specified by the Privacy Policy of the service. Place of Processing: Japan –
Privacy Policy

OTHER CONTACT TOOLS

WhatsApp (WhatsApp Ireland Limited)

WhatsApp is an instant messaging service provided by WhatsApp Ireland Limited. Personal Data Collected: phone number, email, Usage Data, Cookie. Place of Processing: Ireland –
Privacy Policy

EMAIL ADDRESS MANAGEMENT

These services allow you to manage a database of email contacts, telephone contacts, or contacts of any other kind used to communicate with the User. These services may also allow for the collection of Data related to the date and time of the User’s viewing of messages, as well as the User’s interaction with them, such as information about clicks on links embedded in messages.

Newsletter

By registering for the newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, relating to this Web Site may be sent. The User’s email address may also be added to this list as a result of registering with this Site or after making a purchase. The User can choose at any time to unsubscribe from the newsletter by clicking on a specific button they will find within the emails. After clicking the delete button the User’s Data will be deleted immediately from the “email marketing” software. Personal Data Collected: email, phone number, province, First Name, and Last Name. This Web Site uses the newsletter service provided by:

SendinBlue (SendinBlue SAS)

SendinBlue is a service that organizes and analyzes newsletter distribution. In case a User does not want their Data to be managed by SendinBlue, it will be necessary for them to unsubscribe from the newsletter. To this end, a link is provided in each newsletter sent. Personal Data Collected: Email and Name. Place of Processing: FRANCE –

Privacy Policy

CONTENT COMMENTARY

Comment services allow Users to make and make public comments regarding. Users, depending on the settings decided by the Owner, can also leave the comment anonymously. Users are responsible for the content of their comments.

SPAM PROTECTION

These services analyze the traffic of this Website, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

WORDFENCE SECURITY (Defiant, Inc)

To prevent cyber attacks and block suspicious users and IP addresses, this Website uses the Wordfence Security plugin, which installs a technical cookie (wfwaf-authcookie*) that helps determine whether the user has suspicious characteristics. The Owner does not collect, store, or share any personal data via this cookie. The data collected by this plugin is kept for 24 hours.

https://www.wordfence.com/help/general-data-protection-regulation/

https://www.wordfence.com/privacy-policy/

SECURITY MEASURES TAKEN

This Website, to make it secure when Personal Data is entered, has an SSL certificate and uses the HTTPS protocol. With the use of this protocol, the transactions and data that are transmitted in the websites take place with the utmost security and the content of the communication is not read or manipulated in any way by third parties.

reCAPTCHA

This Website uses reCAPTCHA which is a service subject to the

privacy

and the
terms and conditions
of use of Google.

STATISTICS

Statistical services allow the Data Controller exclusively to monitor and analyze traffic data and serve to track User behavior. This Web Site uses the following services:

1. Google Analytics (Google Ireland Limited)

Google Analytics is an analytics service provided by Google Ireland Limited. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its ad network. Google may also transfer this information to third parties where required by law or where such third parties process this information on Google’s behalf. IP address anonymization is enabled on this site. The IP address transmitted by the browser for purposes related to Google Analytics will not be merged with other data already held by Google.

At the following link
https://tools.google.com/dlpage/gaoptout?hl=it
the browser add-on for deactivating Google Analytics is made available by Google. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland –
Privacy Policy

2. Facebook pixel conversion tracking (Meta Platforms, Inc.).

Facebook conversion tracking (Facebook pixel) is a statistics service provided by Facebook. The Facebook pixel monitors conversions that can be attributed to Facebook ads. Personal Data Collected: Cookies; Usage Data. Place of processing: Ireland –

Privacy Policy.

TAG MANAGEMENT

Google Tag manager (Google Ireland Limited)

Google Tag manager is a service that allows you to manage and monitor all third-party Tags on the Website to get information about the interest shown by Users towards the Website itself and consequently the quality of the content. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

INTERACTION WITH SOCIAL NETWORKS

These services allow interactions with social networks directly from the pages of this Website. Interactions and information captured by this Website are in each case subject to the User’s privacy settings related to each social network. In the event that a social network interaction service is installed, it is possible that, even if Users do not use the service, it will collect traffic data related to the pages where it is installed.

1. Facebook (Meta Platforms, Inc.)

Facebook buttons are interaction services with the social network Facebook, provided by Meta Platforms, Inc. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland –
Privacy Policy

2. Instagram (Meta Platforms, Inc.)

Instagram buttons are interaction services with the social network Instagram, provided by Meta Platforms, Inc. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland –
Privacy Policy

3. LinkedIn (LinkedIn Ireland Unlimited Company)

LinkedIn buttons are interaction services with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland –
Privacy Policy

4. WhatsApp (WhatsApp Ireland Limited)

WhatsApp buttons are communication interaction services provided by Whatsapp Ireland Limited. Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland-
Privacy Policy (https://www.whatsapp.com/privacy/?lang=it

)

REMARKETING AND RETARGETING

These services allow this Website to communicate, optimize, and serve advertisements based on the User’s past use of this Website. This activity is carried out through the tracking of Usage Data and the use of Cookies. This Web Site uses the following services:

1. Facebook Remarketing (Meta Platforms, Inc.).

Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, which links this Website’s activity with the Facebook advertising network. This Website makes use of the Facebook Pixel tool in order to measure conversions. Thanks to the Facebook Pixel, you can understand the actions people perform on the Website. The Data you collect may be used for:

– Make sure listings are shown to the right people;

– Create audience groups for which to target advertisements;

– Take advantage of the additional advertising tools of the platform you are advertising on

The information collected is anonymous to the operators of this Site and cannot be used to identify an individual user. However, the information is saved and analyzed by Facebook, which could link the action back to an individual profile and use this information for internal Facebook advertising purposes, as outlined by Facebook’s privacy policy. This will allow Facebook to show advertisements on both Facebook and third-party sites. The Site Owner has no control over how this data is used. For more information on how users can protect their privacy, please refer to the

Privacy

of Facebook.

2. Google ADS

Google ADS is a service provided by Google Ireland Limited that links this Website with Google’s advertising network. This Website makes use of Google Analytics’ Remarketing features combined with Google ADS’s multi-device adaptation capability. This feature makes it possible to link target groups for promotional campaigns created by the Marketing function of Google Analytics with the cross-device adaptability of Google ADS. This allows displaying advertisements based on the user’s personal interests, identified through an analysis of the user’s web behavior, whether on a mobile device or other devices. You can permanently disable targeting and remarketing features by disabling the “personalized advertising” feature in your Google account. To do so, simply follow this link:
https://www.google.com/settings/ads/onweb/
Personal Data Collected: Cookies and Usage Data. Place of processing: Ireland –
Privacy Policy

3. Instagram Remarketing (Meta Platforms, Inc.).

Instagram Remarketing is a Remarketing and Behavioral Targeting service provided by Meta Platforms, Inc. that connects the activity of this Website with the Instagram advertising network. This Website makes use of the Pixel tool in order to measure conversions and understand the actions people perform on the Website. The information collected is anonymous to the operators of this Website and cannot be used to identify an individual user. However, the information is saved and analyzed by Facebook, which could link the action back to an individual profile and use this information for internal Facebook advertising purposes, as outlined by Facebook’s privacy policy. For more information on how users can protect their privacy, please refer to the Instagram privacy.

CONTENT ON EXTERNAL PLATFORMS

These services allow you to view content hosted on external platforms directly from the pages of this Website and interact with them.
In case such a service is installed, it is possible that, even in case Users do not use the service, it will collect Traffic Data related to the pages where it is installed.

This Web Site uses

1. Google Maps

Google Maps is a map display service operated by Google that allows this Website to integrate such content within its pages. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland –

Privacy Policy

2. Youtube (Google Ireland Limited)

Youtube is a video content display service operated by Google that allows this Website to integrate such content within its pages. Personal Data Collected: Cookies and Usage Data. Place of Processing: Ireland –
Privacy Policy

3. Google Fonts

Google Fonts is a font style display service provided by Google Ireland Limited that allows this Web Site to integrate such content within its pages. Personal Data Collected: Usage Data; various types of Data as specified by the service’s privacy policy. Place of processing: Ireland –
Privacy Policy

Exercise of data subject’s rights

The Interested Party has the right to exercise the faculties provided for in Articles 7, 15-22 of Reg. European 679/2016. In particular, he/she has the right to revoke his/her consent at any time and, upon simple request to the Data Controller, may request access to the Personal Data, receive the Personal Data provided to the Data Controller and where possible transmit it to another Data Controller without hindrance (so-called portability), obtain the updating, restriction of processing, rectification of Data and the deletion of Data processed in contravention of applicable regulations. He/she has the right, for legitimate reasons, to object to the Processing of Personal Data concerning him/her and to the Processing for the purpose of sending advertising material, direct sales and for carrying out market research. It also has the right to file a complaint with the Garante della Privacy as the data protection supervisory authority. Data subjects may exercise their rights by contacting the Owner by e-mail at: info@togoloco.com

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Therefore, please consult this page often, taking the date of last modification shown at the bottom as a reference. If you do not accept the changes made to this Privacy Policy, you must cease using this Website and may request the Data Controller to remove your Personal Data. Unless otherwise specified, the previous Privacy Policy will continue to apply to Personal Data collected up to that point. The Owner is not responsible for updating all links viewable in this Privacy Policy, so whenever a link is not working and/or updated, Users acknowledge and agree that they should always refer to the document and/or section of the websites referred to by that link.

Privacy Policy updated as of April 2022