PRIVACY POLICY

Wisepath considers your privacy to be of fundamental importance and tries to ensure that the processing of your personal data is carried out in compliance with the rights, fundamental freedoms, as well as the dignity of the interested party, with particular reference to confidentiality, personal identity and the right to the protection of personal data.

In this regard, Wisepath has adopted and implemented a Privacy Policy concerning all the methods of managing the activities that involve the processing of your personal data.

This Privacy Policy explains how and why Wisepath collects, records and uses information about you and the choices you can make about how that information is collected and used.

REGISTRATION
In order to use the Service or part of it, Users must register by truthfully and completely providing all the data requested in the relevant registration form and fully accept the privacy policy and these general conditions. The user has the responsibility to guard and keep his access credentials confidential. It is understood that under no circumstances will Wisepath be held responsible in the event of loss, dissemination, theft or unauthorized use by third parties, for any reason whatsoever, of the Users' access credentials.
 

To create an account on Wisepath you must be at least 16 years old. In order to verify the existence of the minimum age, Wisepath reserves the right to request, during the registration process, to enter one's date of birth.

OWNER OF THE TREATMENT
The data controller is Wisepath Corp., with headquarters in 17642 Plumeria Ln, Dallas, TX, 75252, in the person of its pro tempore legal representative, Mr. Gianluca Ferremi.

In this document it will be referred to as Wisepath, which is the distinctive sign under which it carries out any activity on the Site.
The data controller can be contacted to the email address info@wisepath.ai

A Data Protection Officer (DPO) has not been appointed.

TYPES OF DATA COLLECTED
Among the Personal Data collected, independently or through third parties, or freely provided by the User, there are:

Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and website addresses from which access was made, information on the pages visited by users within of the site, the time of access, the permanence on the single page, the analysis of the internal path and other parameters relating to the operating system and the user's IT environment.

Additional Data Categories
This is all Personal Data provided by the User through the site, for example, by registering and/or accessing a reserved area and/or a service and/or participating in one of the initiatives provided by Wisepath or in partnership with third parties or by writing to an e-mail address to request information or by subscribing to the newsletter.

The Personal Data collected is used to provide services to the User and to send communications by e-mail, the address of which is provided at the time of registration.
 

If access to the site takes place under the profile of "Mentor", the user agrees that the data provided at the time of registration will be used by the platform for the guidance services to be provided and for the possibility of being contacted by other users.
The newsletter service consists in sending electronic communications following the express request of the recipient, for which it is not necessary to acquire a further consent, other than that provided by the recipient when completing and sending the newsletter subscription form. However, it is necessary that the user can see the privacy information (possibly even if linked) and click on the newsletter subscription button, after filling in the required fields.
 

Any use of Cookies - or other tracking tools - by Wisepath unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the other purposes described in the Cookie Policy.

MANDATORY DATA AND OPTIONAL DATA
Unless otherwise specified, all Personal Data requested by www.wisepath.ai are mandatory. If the User refuses to communicate them, it may be impossible for Wisepath to provide the Service. In cases where www.wisepath.ai indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory are encouraged to contact the Owner.

LEGALITY AND PURPOSE OF THE TREATMENT
The processing of personal data takes place in accordance with the provisions of the General Data Protection Regulation (GDPR) and any other applicable data protection legislation. The details are provided below:

* Purposes aimed at fulfilling a legal obligation (Article 6, paragraph 1 (c) of the GDPR)
a. Fulfillment of obligations established by Laws, Regulations and European Union legislation, or by provisions issued by Authorities or by Supervisory and Control Bodies in relation to or in any case connected to the existing and/or future legal relationship.
The retention period of personal data, in relation to the purposes referred to in this section, is 10 years, from the end of the legal or commercial relationship established. These times may be extended in the event of a dispute or legal provision.

* Purposes aimed at the execution of a contract or pre-contractual measures (Article 6, section 1 (b) of the GDPR)
to. fulfillment of contractual obligations and deriving from legal transactions and in particular of the finalized agreement, i.e. registration on the Site

b. Conclusion of a sale and protection of contractual rights or in any case deriving from the relationships between the parties.
The retention period of personal data, in relation to the purposes referred to in this section, is:

For the purposes: a) until the cancellation of the profile, and for a subsequent period not exceeding one quarter from such cancellation or from the deactivation of the profile;

For the purpose: b) 10 years, from the end of the established legal or commercial relationship. These times may be extended in the event of a dispute or due to special contractual provisions.
 

* Purposes covered by the consent of the interested party (Article 6, paragraph 1 (a) of the GDPR) The purposes may require the consent expressed by the interested party.

The purposes that require consent are:
a. carrying out advertising or promotional activities, in the broadest sense of the term (for example orientation services, communication of the user's profile following the completion of the questionnaire, sending of newsletters and information material, requesting brochures, organizing of events, etc.) and other marketing activities, through telephone contacts, e-mail, ordinary mail and SMS, various instant messaging systems, social network accounts and any tool or form of electronic communication, including reporting of all the initiatives dedicated to registered users;

b. the performance of profiling activities, such as the analysis of the user's consumption habits or choices, mainly using the data entered during registration on the Site, data relating to his participation in surveys, questionnaires and market research in general performed, as well as data relating to the services used, and other behaviors and data that the Data Controller should know in any way, including any data deriving from any analysis of web browsing or from the analysis of any cookies installed through its website.

c. reporting of contacts of different users registrations on the platform.
The retention period of personal data, in relation to the purposes referred to in this section, is at least 24 months from the issue of consent, unless revoked.

The interested party can withdraw his consent at any time, with the understanding that the withdrawal of consent has effect only for the future. Any data processing that took place before the revocation will not be affected and will retain its legitimacy.
 

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

METHOD AND PLACE OF THE PROCESSING OF THE COLLECTED DATA
The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools (and storage via cloud made available on the Amazon web Services platform), with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the Wisepath organization (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller.

The updated list of Managers can always be requested from the Data Controller.
 

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner.
 

The Data Controller informs you that he has no intention of transferring his data to countries outside the EU and the EEA for the purposes indicated above.

INTERACTIONS WITH OTHER USERS
The communication services between Users allow forms of interaction and contact, depending on the settings decided by the Owner, anonymously or publicly. If there is an email among the Personal Data released by the User, this could be used to send notifications of comments, interactions and contacts. Users are solely responsible for the content of their comments, posts and interactions.

YOUR RIGHTS
Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:

*    revoke consent at all times. The User can revoke the previously expressed consent to the processing of his Personal Data.

*    oppose to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.

*    log into to their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

*    check and askthe rectification. The User can verify the correctness of his Data and request its updating or correction.

*    obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.

*    obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.

*    receive their data or have them transferred to another holder. The User has the right to receive his Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.

*    propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue 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 without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

To exercise the User's rights, Users can address a request to the contact details of the Owner at mail info@wisepath.ai. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

RIGHT TO PROPOSE A COMPLAINT
If the User believes that their rights have been compromised, they have the right to lodge a complaint with the Guarantor Authority for the protection of personal data, according to the methods indicated by the same Authority at the following Internet address:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or by sending a written communication to the Personal Data Protection Authority, Piazza Montecitorio n.121, 00186 Rome .

CONSENT PURSUANT TO ART. 7 OF EU REGULATION 2016/679
In compliance with the provisions of art. 7 of the EU Regulation, the User declares to have fully understood the information provided by the Data Controller and:

* in relation to: carrying out advertising or promotional activities, in the broadest sense of the term (for example orientation services, communication of the user's profile following completion of the questionnaire, sending of newsletters and information material, request for brochures, organization of events, etc.) and other marketing activities, through telephone contacts, e-mails, ordinary mail and SMS, various instant messaging systems, social network accounts and any tool or form of communication electronic, including reporting of all initiatives dedicated to registered users;

* in relation to: the performance of profiling activities, such as the analysis of the user's consumption habits or choices, mainly using the data entered during registration on the Site, the data relating to his participation in surveys, questionnaires and in market research carried out, as well as data relating to the services used, and other behaviors and data that the Data Controller should know in any way, including any data deriving from any analysis of web browsing or from the analysis of any cookies installed through the own site.

* in relation to: reporting of contacts of various users registrations on the platform.

The Owner, without prejudice to the full freedom of the User, and in compliance with the rights granted to him, to provide his free consent, informs that in relation to the purposes indicated above, even a partial consent may not guarantee the pursuit of the single purpose, for which consent was partially denied.

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COOKIE POLICY

Use of Cookies
When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information could be about you, your preferences or your device and is mostly used to make the site work according to your expectations. The information does not usually directly identify you, but it can provide a more personalized web experience. Because we respect your right to the protection of your personal data, you can choose not to allow some types of cookies. However, the inhibition of some types of cookies can have consequences on your navigation on the site and on the use of the related services that we are able to offer.

Further information
The following information is provided to the user in implementation of the provision of the Guarantor for the protection of personal data of 8 May 2014 "Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies" and in compliance to the GDPR EU Reg. 2016/679.

What are Cookies? And which cookies do we use?
Cookies are small text strings that a website can send, while browsing, to your device (be it a PC, a notebook, a smartphone, a tablet; usually they are stored directly on the browser used for browsing) . The same website that transmitted them can read and record the cookies that are located on the same device to obtain various types of information. Which? For each type of cookie there is a well-defined role.

We use cookies and pixel tags to track our Users' use of the Sites and to understand their preferences (such as country and language choices). This allows us to provide services and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends and obtain statistics so that we can always improve our Sites.

In general, Wisepath collects and records information from your browser as you use the site, which may also include personal data. We use a variety of methods, such as cookies and pixel tags, to collect this information, which may include: (i) your IP address; (ii) unique cookie identifier, cookie information, and information about whether or not device software is available to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Sites, such as clicks made, purchases and preferences indicated;

Third parties may also collect information from the Sites through cookies, third-party plug-ins and widgets. The third parties collect data directly from your web browser and the processing and treatment of the aforementioned data is subject to their respective privacy regulations

How many types of cookies are there?
There are two macro-categories, with different characteristics: technical cookies and profiling cookies.

Technical cookies are generally necessary for the correct functioning of the website and to allow navigation; without them you may not be able to view the pages correctly or use some services. For example, a technical cookie is essential to keep the user connected throughout the visit to a website, or to memorize the language settings, display settings, and so on.
The technical cookies used on this site can be further divided into:

Necessary cookies
These cookies are necessary for the site to function, with particular reference to normal navigation and use of the same, and cannot be deactivated in our systems. They are usually only set in response to actions you take that constitute a request for services, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block these cookies, but some or all parts of the site will not work as a result. These cookies do not store personal information.

Analytical cookies
These cookies allow visits and traffic sources to be counted in order to evaluate and improve the performance of the site. All information collected by cookies is aggregated and therefore anonymous. If you do not authorize these cookies, we will not be able to evaluate navigation and the collective behavior of our users and consequently improve the performance of the site.

Functionality cookies
These cookies allow the site to provide advanced features and customization, which allow navigation according to a series of selected criteria (for example, the language, the products selected for purchases) in order to improve the service. They can be set by us or by third-party providers whose services have been added to our pages. If you do not authorize these cookies, some or all of these services may not work properly.

Profiling cookies have the task of profiling the user and are used in order to send advertising messages in line with the preferences expressed by the same during his navigation
 

These cookies can also be set, through our site, only by our advertising partners and therefore are third-party cookies. These cookies are based solely on identifying your browser and internet device. If you do not allow these cookies, you will not be shown or sent the aforementioned advertisements, nor will profiles of your interests be created. The refusal or withdrawal of consent to the use of one or more profiling cookies will not interfere with the possibility of accessing the Site or browsing on it.
 

The use of these cookies requires the prior acquisition of the user's free consent.
 

You can always change your preference by visiting the Cookie Policy at the bottom of each page of our Sites.

Interaction with social networks and external platforms
Social media related cookies offer the ability to connect to social networks and share content from our site through social media. Advertising cookies (of third parties) collect information to help better tailor ads to your interests, both on and off our Sites. In some cases, these cookies involve the processing of your personal data. Rejecting these cookies may result in the display of advertisements that are not relevant to the user or the inability to connect effectively via Facebook, Twitter or other social networks and/or to share content on social media. You are not expected to interact with such platforms.

Statistics


The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google)
Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the advertisements of its advertising network.
Personal data collected: Cookies and usage data. 
Place of processing: USA
 

Privacy policy https://policies.google.com/privacy?hl=it
 

Opt out: https://tools.google.com/dlpage/gaoptout?hl=it
 
Duration of cookies
Cookies have a duration dictated by the expiration date (or by a specific action such as closing the browser) set at the time of installation.

Cookies, in this sense, can be:

* temporary or session: they are used to store temporary information, allow you to link the actions performed during a specific session and are removed from the computer when the browser is closed;
 

* permanent: they are used to store information, such as the login name and password, in order to avoid the user having to type them again each time he visits a specific site. These remain stored on your computer even after you close your browser.

Cookie management
The User can deny his consent and/or modify his options relating to the use of cookies by this Cookie Policy at any time, by accessing the same which can be "linked" from every page of this Site.

How to disable/delete cookies by configuring the browser

Chrome
Run Chrome Browser
Click on the menu in the browser toolbar next to the url entry window for navigation
Select Settings
Click Show Advanced Settings
In the "Privacy" section, click on the Content Settings button
In the "Cookies" section, you can change the following cookie settings:
- Allow saving data locally
- Change the local data only until the browser is closed
- Prevent sites from setting cookies
- Block third-party cookies and site data
- Manage exceptions for some internet sites
- Delete one or all cookies
For more information, visit the dedicated page.

MozillaFirefox
Run the Mozilla Firefox Browser
Click on the menu in the browser toolbar next to the url entry window for navigation
Select Options
Select the Privacy panel
Click Show Advanced Settings
In the "Privacy" section, click on the Content Settings button
In the Tracking section, you can change the following cookie settings:
- Request sites not to do any tracking
- Communicate to the sites the availability to be tracked
- Do not communicate any preferences regarding the tracking of personal data
From the History section you can:
- By enabling "Use custom settings", select to accept third-party cookies (always, from the most visited or never visited sites) and to keep them for a specific period (until they expire, close Firefox or ask each time)
- Remove individual stored cookies.
For more information, visit the dedicated page.

Internet Explorer
Run the Internet Explorer Browser
Click the Tools button and choose Internet Options
Click on the Privacy tab and, in the Settings section, change the slider according to the desired action for the cookies:
- Block all cookies
- Allow all cookies
- Select the sites from which to obtain cookies: move the cursor to an intermediate position so as not to block or allow all cookies, then press on Sites, in the Web Site Address box enter an internet site and then press on Block or Allow.
For more information, visit the dedicated page.

Safari 6
Run the Safari Browser
Click on Safari, select Preferences and click on Privacy
In the Block Cookies section, specify how Safari must accept cookies from websites.
To view which sites have stored cookies, click on Details
For more information, visit the dedicated page.

Safari iOS (mobile devices)
Run the iOS Safari Browser
Tap on Settings and then Safari
Touch Block Cookies and choose from the various options: "Never", "Third-party and advertisers" or "Always"
To delete all cookies stored by Safari, tap on Settings, then on Safari and finally on Clear Cookies and Data
For more information, visit the dedicated page.

Opera
Run the Opera Browser
Click on Preferences then on Advanced and finally on Cookies
Select one of the following options:
- Accept all cookies
- Accept cookies only from the site you are visiting: third-party cookies and those sent from a domain other than the one you are visiting will be rejected
- Never accept cookies: all cookies will never be saved.