- Types of Data collected
- How do we collect your Data
- How will we use your data?
- The rights of Users
- How to contact us
Types of Data collected
Among the types of Personal Data that Sticky Brand collects, by itself or through third parties, there are: Usage Data; email address; first name; last name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); and various types of Data you provided to us or, in case of Usage Data, collected automatically when using Sticky Brand.
By using our website and/or the Service, you are consenting to the collection and use of information, including your Personal Information, in accordance with this policy.
How we collect your Data
Methods of processing to keep your information secure
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 Sticky Brand (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 Data is securely stored and processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. We have taken security precautions including appropriate technical and organizational measures to safekeeping the data. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. You can inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as necessary to provide you with the Service and for legitimate and essential business purposes. We keep some of your personal data for as long as you are a user of the Service. For example, we keep your account information.
- 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 fulfill 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 retains 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 shall 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.
How do we use your data?
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Tag Management, Analytics, User database management, Remarketing and behavioral targeting, Contacting the User, Advertising, Handling payments, Registration and authentication, Hosting and backend infrastructure, Social features and Displaying content from external platforms. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. Unless specified otherwise, all Data requested by Sticky Brand is necessary to provide you with all services requested and failure to provide this Data may make it impossible for Sticky Brand to provide its services. Users are free to choose not to provide us with additional Data other than Data requested by Sticky Brand without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is necessary to enable our services or would like to have further information about Personal Data collected are welcome to contact the Owner.
Registration and authentication
By registering or authenticating, Users allow Sticky Brand 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, Sticky Brand will be able to access some Data, stored by these third-party services, for registration or identification purposes.
- Google OAuth (Google LLC)
Contacting the User
We use your personal information to communicate with you in relation to the services we provided:
- Mailing list or newsletter (Sticky Brand)
- Contact form (Sticky Brand)
- Displaying content from external platforms
Payment processing services enable Sticky Brand to process payments by credit card, bank transfer or other means. To ensure greater security, Sticky Brand shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
- Stripe (Stripe Inc)
- PayPal (PayPal Inc.)
- Amazon Pay
- Apple Pay
System logs and maintenance
For operation and maintenance purposes, Sticky Brand and any third-party services may collect files that record interaction with Sticky Brand (System logs) use other Personal Data (such as the IP Address) for this purpose.
Legal action and compliance with laws
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 Sticky Brand 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.
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Sticky Brand, possibly based on User interests.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
- Google Analytics (Google LLC)
- Google Ads conversion tracking (Google LLC)
- Google Analytics Advertising Reporting Features (Google LLC)
- User ID extension for Google Analytics (Google LLC)
- Analytics collected directly (Sticky Brand)
- Yahoo Advertising conversion tracking (Yahoo! Inc.)
- Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
- Twitter Ads conversion tracking (Twitter, Inc.)
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Sticky Brand to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Sticky Brand. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
- Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Remarketing and behavioral targeting
This type of service allows Sticky Brand and its partners to inform, optimize and serve advertising based on past use of Sticky Brand by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists.
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 Ads Remarketing (Google LLC)
- Remarketing with Google Analytics (Google LLC)
- Facebook Custom Audience (Facebook, Inc.)
- Facebook Remarketing (Facebook, Inc.)
Sticky Brand 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.
This type of service helps the Owner to manage the tags or scripts needed on Sticky Brand in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Sticky Brand, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving Sticky Brand. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Sticky Brand.
Legal basis of processing personal Information
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.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
Your right to opt-out
You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing your data based on consent provided before its withdrawal. You may contact us anytime to opt-out of:
- direct marketing communications
- automated decision-making and/or profiling
- our collection of Sensitive Personal Data
Your right to access Data
You may access the Data we hold about you at any time by contacting us directly. You can also contact us to update or correct any inaccuracies in your Personal Information. If you wish to exercise any of these rights, please contact us. Users entitled to broader protection standards under EU General Data Protection Regulation may exercise any of the rights described below.
- 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.
Applicability of broader protection standards under EU General Data Protection Regulation
Broader protection standards apply when the processing:
- is performed by an Owner based within the EU;
- concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
- concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.
If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization 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.
Information for Californian consumers
Categories of personal information collected, disclosed or sold
In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers and internet information. We will not collect additional categories of personal information without notifying you.
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Sticky Brand. For example, you directly provide your personal information when you submit requests via any forms on Sticky Brand. You also provide personal information indirectly when you navigate Sticky Brand, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Sticky Brand and features thereof.
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service. To find out more about the purposes of processing, please refer to the relevant section of this document.
Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
Sticky Brand does not share any text messaging originator opt-in data and consent with any third parties.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of Sticky Brand and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:
- the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
- in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
- for sales, the personal information categories purchased by each category of recipient; and
- for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
The disclosure described above will be limited to the personal information collected or used over the past 12 months. If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Sticky Brand, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Sticky Brand, both online and offline, you can contact us for further information using the contact details provided in this document.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12 month period. Should we deny your request, we will explain you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
How to manage cookies
Sticky Brand does not support “Do Not Track” requests. You can set your browser not to accept cookies, and please see how to remove cookies from allaboutcookies.org. However, in a few cases, some of our website features may not function as a result. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
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.
Information collected automatically through Sticky Brand (or third-party services employed in Sticky Brand), which can include: the IP addresses or domain names of the computers utilized by the Users who use Sticky Brand, 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.
The individual using Sticky Brand who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
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 Sticky Brand. The Data Controller (or Owner), unless otherwise specified, is Sticky Brand Creative Group, LLC.
The means by which the Personal Data of the User is collected and processed.
The service provided by Sticky Brand 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 are text files stored in the User’s device to collect standard Internet log information and visitor behavior information.
How to contact us
Email us at: email@example.com
Or write to us at the following address:
208 Flynn Ave,
Latest update: July 13, 2021.