IMMIGRAM
Privacy Policy of immigram.io
Sterling Startup Solutions Limited (hereafter "Immigram") collects some Personal Data from its Users.


Owner and Data Controller
Sterling Startup Solutions Limited, a company registered in England under company number 11946440 with a registered office address at 35 Berkeley Square, Mayfair, London, England, W1J 5BF
Owner contact email: network@immigram.io


Types of Data collected
Among the types of Personal Data that Immigram collects, by itself or through third parties, there are: first name; last name; email address; personal information in the Immigram Questionnaire located at https://immigram.io/app; Cookies; Usage Data; various types of Data; address; geographic position; country; username; password.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Immigram.

Unless specified otherwise, all Data requested by Immigram is mandatory and failure to provide this Data may make it impossible for Immigram to provide its services. In cases where Immigram specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by Immigram or by the owners of third-party services used by Immigram serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Immigram and confirm that they have the third party's consent to provide the Data to the Owner.


Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Immigram (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Access to third-party accounts, Analytics, Advertising, Content commenting, Data transfer outside the EU, Displaying content from external platforms, Handling payments, Interaction with external social networks and platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, Remarketing and behavioural targeting, Social features and SPAM protection.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.


Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

  • Access to third-party accounts
This type of service allows Immigram to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically but require explicit authorisation by the User.

Stripe account access (Stripe Inc)

This service allows Immigram to connect with the User's account on Stripe, provided by Stripe, Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • Advertising
This type of service allows User Data to be utilised for advertising communication purposes displayed in the form of banners and other advertisements on Immigram, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Cookies to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User's interests and behaviour, including those detected outside Immigram. For more information, please check the privacy policies of the relevant services. In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain advertising features by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google AdSense (Google Ireland Limited)

Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the "DoubleClick" Cookie, which tracks use of Immigram and User behaviour concerning ads, products and services offered.

Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.

  • Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google utilises the Data collected to track and examine the use of Immigram, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the ads of its own advertising network. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.

Google Analytics with anonymised IP (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google utilises the Data collected to track and examine the use of Immigram, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.

  • Contacting the User
Contact form & Questionnaire (Immigram)

By filling in the contact form with their Data, the User authorises Immigram to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header. Personal Data collected: email address; first name; last name, various personal information collected through Questionnaire located at https://immigram.io/app.

Mailing list or newsletter (Immigram)

By registering on the mailing list or for the newsletter, the User's email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Immigram. Your email address might also be added to this list as a result of signing up to Immigram or after making a purchase. Personal Data collected: email address; first name; last name, various personal information collected through Questionnaire located at https://immigram.io/app.

  • Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Immigram. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform. Personal Data collected: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

  • Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on consent (Immigram)

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Immigram. Personal Data collected: various types of Data.

  • Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Immigram and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows Immigram to incorporate content of this kind on its pages. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Google Maps widget (Google Ireland Limited)

Google Maps is a maps visualisation service provided by Google Ireland Limited that allows Immigram to incorporate content of this kind on its pages. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

Google Site Search (Google Ireland Limited)

Google Site Search is a search engine embedding service provided by Google Ireland Limited that allows Immigram to incorporate content of this kind on its pages. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.

  • Handling payments
Unless otherwise specified, Immigram may process any payments by credit card, bank transfer or other means via external payment service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Immigram isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.

Android Pay (Google Ireland Limited)

Android Pay is a payment service provided by Google Ireland Limited, which allows Users to make payments using their mobile phones. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Ireland – Privacy Policy.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Payment by bank transfer (Immigram)

In the event that the chosen payment method is a direct bank transfer to the current account indicated by Immigram, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only. Personal Data collected: address; first name; last name; payment data.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: See the PayPal privacy policy –Privacy Policy.

WorldPay (WorldPay Limited)

WorldPay is a payment service provided by WorldPay Limited. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United Kingdom – Privacy Policy.

  • Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Immigram. The interaction and information obtained through Immigram are always subject to the User's privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on Immigram isn't being connected back to the User's profile.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data collected: Cookies; Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

PayPal button and widgets (PayPal Inc.)

The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc. Personal Data collected: Cookies; Usage Data. Place of processing: See the PayPal privacy policy –Privacy Policy.

  • Location-based interactions

Geolocation (Immigram)

Immigram may collect, use, and share User location Data in order to provide location-based services Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User's location data may be tracked by Immigram. Personal Data collected: geographic position.



Non-continuous geolocation (Immigram)



Immigram may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User's location data may be tracked by Immigram. The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically. Personal Data collected: geographic position.



Managing contacts and sending messages


This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.



Mailchimp (The Rocket Science Group LLC)



Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC. Personal Data collected: Cookies; country; email address; first name; last name; Usage Data; various types of Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.



Customerly E-mail Marketing (Customerly Ltd.)



Customerly E-mail Marketing is an email address management and message sending service provided by Customerly Ltd. Personal Data collected: Cookies; country; email address; first name; last name; Usage Data; username; various types of Data. Place of processing: Ireland – Privacy Policy.



Registration and authentication


By registering or authenticating, Users allow Immigram to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Immigram will be able to access some Data, stored by these third-party services, for registration or identification purposes.



Direct registration (Immigram)



The User registers by filling out the registration form and providing the Personal Data directly to Immigram. Personal Data collected: address; billing address; country; data relating to the point of sale; email address; first name; last name; password; shipping address; VAT Number; ZIP/Postal code, various personal information collected through Questionnaire located at https://immigram.io/app.



Stripe OAuth (Stripe Inc)



Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy. Privacy Shield participant.



Remarketing and behavioural targeting


This type of service allows Immigram and its partners to inform, optimise and serve advertising based on past use of Immigram by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioural targeting activity. Some services offer a remarketing option based on email address lists.



In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain remarketing features by visiting the Network Advertising Initiative opt-out page.



Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.



Remarketing with Google Analytics (Google Ireland Limited)



Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.



Social features




Inviting and suggesting friends (Immigram)



Immigram may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it. Personal Data collected: various types of Data.



SPAM protection


This type of service analyses the traffic of Immigram, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.



Google reCAPTCHA (Google Ireland Limited)



Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.



Further information about Personal Data



Analysis and predictions based on the User's Data ("profiling")


The Owner may use the Personal and Usage Data collected through Immigram to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document. User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document. The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.



Personal Data collected through sources other than the User


The Owner of Immigram may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.



Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.



Push notifications


Immigram may send push notifications to the User to achieve the purposes outlined in this privacy policy.



Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Immigram, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of Immigram.



Push notifications based on the User's geographic location


Immigram may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.



Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of Immigram.



Push notifications for direct marketing


Immigram may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Immigram).



Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for Immigram or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of Immigram. Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.



Selling goods and services online


The Personal Data collected may be used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Immigram depends on the payment system used.



The Service is not directed to children under the age of 18


Users declare themselves to be adult according to their applicable legislation. Minors may use Immigram only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Immigram.



The rights of Users



Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.



Details about the right to object to processing



Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.



Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.



How to exercise these rights



Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.



Cookie Policy



Cookies consist of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes for which Cookies are installed may also require the User's consent.



Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time following the instructions provided in this document.



Technical Cookies and Cookies serving aggregated statistical purposes



Activity strictly necessary for the functioning of the Service


Immigram.io/ uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of Immigram.io/, for example in relation to the distribution of traffic.



Activity regarding the saving of preferences, optimization, and statistics


Immigram.io/ uses Cookies to save browsing preferences and to optimize the User's browsing experience. Among these Cookies are, for example, those used for the setting of language and currency preferences or for the management of first party statistics employed directly by the Owner of the site.



Other types of Cookies or third parties that install Cookies

Some of the services listed below collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner - depending on how they are described - without the help of third parties.



If any third party operated services are listed among the tools below, these may be used to track Users' browsing habits – in addition to the information specified herein and without the Owner's knowledge. Please refer to the privacy policy of the listed services for detailed information.



Advertising


This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Immigram.io/, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User's interests and behaviour, including those detected outside Immigram.io/. For more information, please check the privacy policies of the relevant services.



In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain advertising features by visiting the Network Advertising Initiative opt-out page.



Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.



Google AdSense (Google Ireland Limited)



Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the "DoubleClick" Cookie, which tracks use of Immigram.io/ and User behaviour concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

Personal Data collected: Cookies and Usage Data.

Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.



Analytics


The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.



Google Analytics (Google Ireland Limited)



Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google utilizes the Data collected to track and examine the use of Immigram.io/, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.



Google Analytics with anonymized IP (Google Ireland Limited)



Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google utilizes the Data collected to track and examine the use of Immigram.io/, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.



Content commenting


Content commenting services allow Users to make and publish their comments on the contents of Immigram.io/. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.



Facebook Comments (Facebook, Inc.)



Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.



Displaying content from external platforms


This type of service allows you to view content hosted on external platforms directly from the pages of Immigram.io/ and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.



Google Maps widget (Google Ireland Limited)



Google Maps is a maps visualization service provided by Google Ireland Limited that allows Immigram.io/ to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.



Google Site Search (Google Ireland Limited)



Google Site Search is a search engine embedding service provided by Google Ireland Limited that allows Immigram.io/ to incorporate content of this kind on its pages. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.



Interaction with external social networks and platforms


This type of service allows interaction with social networks or other external platforms directly from the pages of Immigram.io/. The interaction and information obtained through Immigram.io/ are always subject to the User's privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on Immigram.io/ isn't being connected back to the User's profile.



Facebook Like button and social widgets (Facebook, Inc.)



The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.



PayPal button and widgets (PayPal Inc.)



The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc. Personal Data collected: Cookies and Usage Data. Place of processing: See the PayPal privacy policy – Privacy Policy.



Managing contacts and sending messages


This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.



Mailchimp (The Rocket Science Group LLC)



Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC. Personal Data collected: Cookies, country, email address, first name, last name, Usage Data and various types of Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.



Customerly E-mail Marketing (Customerly Ltd.)



Customerly E-mail Marketing is an email address management and message sending service provided by Customerly Ltd. Personal Data collected: Cookies, country, email address, first name, last name, Usage Data, username and various types of Data. Place of processing: Ireland – Privacy Policy.



Remarketing and behavioural targeting


This type of service allows Immigram.io/ and its partners to inform, optimize and serve advertising based on past use of Immigram.io/ by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioural targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain remarketing features by visiting the Network Advertising Initiative opt-out page.



Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.



Remarketing with Google Analytics (Google Ireland Limited)



Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out. Privacy Shield participant.



SPAM protection


This type of service analyses the traffic of Immigram.io/, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.



Google reCAPTCHA (Google Ireland Limited)



Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy. Privacy Shield participant.



How to provide or withdraw consent to the installation of Cookies

In addition to what is specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing Cookies. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website. Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.



With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party's privacy policy, or by contacting the third party.



Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI(Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.



Owner and Data Controller



Sterling Startup Solutions Limited, a company registered in England under company number 11946440 with a registered office address at 35 Berkeley Square, Mayfair, London, England, W1J 5BF

Owner contact email: network@immigram.io



Since the installation of third-party Cookies and other tracking systems through the services used within Immigram.io/ cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.



Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by Immigram.io/.



Additional information about Data collection and processing



Legal action



The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Immigram or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.



Additional information about User's Personal Data



In addition to the information contained in this privacy policy, Immigram may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.



System logs and maintenance



For operation and maintenance purposes, Immigram and any third-party services may collect files that record interaction with Immigram (System logs) use other Personal Data (such as the IP Address) for this purpose.



Information not contained in this policy



More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.



How "Do Not Track" requests are handled



Immigram does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honour the "Do Not Track" requests, please read their privacy policies.



Changes to this privacy policy



The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Immigram and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.



Definitions and legal references


Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.



Usage Data



Information collected automatically through Immigram (or third-party services employed in Immigram), which can include: the IP addresses or domain names of the computers utilized by the Users who use Immigram, 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 received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.



User



The individual using Immigram who, unless otherwise specified, coincides with the Data Subject.



Data Subject



The natural person to whom the Personal Data refers.



Data Processor (or Data Supervisor)



The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.



Data Controller (or Owner)



The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Immigram. The Data Controller, unless otherwise specified, is the Owner of Immigram.



Immigram.io(or Immigram)



The means by which the Personal Data of the User is collected and processed.



Service



The service provided by Immigram as described in the relative terms (if available) and on this site/application.



European Union (or EU)



Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.



Cookies



Small sets of data stored in the User's device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Immigram, if not stated otherwise within this document.