Privacy Policy

Privacy Policy | Cookie Policy | Disclaimer

Trivia: privacy in Italian is riservatezza, but the english word has been assimilated in both the speaking and the writing language. Privacy Policy translates to polizza sulla riservatezza but you’ll see polizza sulla privacy more often.

Introduction

Welcome to Daily Italian Words’ privacy notice.

Daily Italian Words respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Table of Contents

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. California Consumer Privacy Act (CCPA)
11. Mediavine Programmatic Advertising
12. Newsletter Sponsorships
13. Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Daily Italian Words collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Daily Italian Words is run by Mathieu Gasquet and Heather Broster which have a registered partnership called MirrorLessons. They are the controller and responsible for your personal data (collectively referred to as “Daily Italian Words”, “MirrorLessons” “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: MirrorLessons
  • Name of data privacy manager: Mr Mathieu Gasquet
  • Email address: mathieu [dot] gasquet [at] gmail [dot] com
  • Postal address: MirrorLessons, PO Box 69, Tywyn, LL36 6AL, UK

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of any changes

This version was last updated on September 11th 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name and last name.
  • Contact Data includes email address.
  • Technical Data includes internet protocol (IP) address (note, IP addresses are anonymised in Google Analytics meaning they end in an 0, so we do not see the precise address), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or if we need to under the terms of a contract we have with you in future, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with any future services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • subscribe to our newsletter;
  • contact us via our contact form;
  • request marketing to be sent to you; or
  • enter a competition, promotion or survey.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

  • Technical Data from analytics providers such as Google based outside the EU;
  • Technical Data from newsletter providers such as ConvertKit based in the US.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful bases that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.

PURPOSE/ACTIVITY 1

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy – (b) Asking you to leave a review or take a survey.

Type of data:

  • (a) Identity
  • (b) Contact
  • (c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

  • (a) Performance of a contract with you
  • (b) Necessary to comply with a legal obligation
  • (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

PURPOSE/ACTIVITY 2

To enable you to partake in a prize draw, competition or complete a survey.

Type of data:

  • (a) Identity
  • (b) Contact
  • (c) Usage
  • (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

PURPOSE/ACTIVITY 3

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Type of data:

  • (a) Identity
  • (b) Contact
  • (c) Technical

Lawful basis for processing including basis of legitimate interest:

  • (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • (b) Necessary to comply with a legal obligation

PURPOSE/ACTIVITY 4

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Type of data:

  • (a) Identity
  • (b) Contact
  • (c) Usage
  • (d) Marketing and Communications
  • (e) Technical

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to study how customers use our websites, to develop them, to grow our business and to inform our marketing strategy)

PURPOSE/ACTIVITY 5

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

Type of data:

  • (a) Technical
  • (b) Usage

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

PURPOSE/ACTIVITY 6

To make suggestions and recommendations to you about goods or services that may be of interest to you.

Type of data:

  • (a) Identity
  • (b) Contact
  • (c) Technical
  • (d) Usage

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers for us

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Advertising

We display adverts on our websites, which involves using third-party companies to serve the content of those advertisements. These third-parties may use cookies; please see our cookies policy by clicking here. To know more about advertising on this website, please check chapter 11.

Affiliate Program Participation

Our websites engage in affiliate marketing, which means embedding tracking links are placed into our websites and if you click on an affiliate link, a cookie will be placed on your browser to track any sales for purposes of commission we receive.

For dailyitalianwords.com, we are participants in the following affiliate programs: LingQ and Lingopie.

We are also a participant in the Amazon Services LLC Associates Program and Amazon EU Associates Programme, which enable us to earn advertising fees and links to Amazon.com and Amazon.co.uk. As such, our websites post customized links, supplied by Amazon, in order to track referrals to their website and Amazon use tracking cookies, to track any sales for the purposes of assigning commission.

Third-Party marketing

We will get your express opt-in consent before we share your personal data with any company outside Daily Italian Words for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Cookies

In order to proceed to use our website, we do require your consent over your cookie settings in respect of our advertising cookies.  In particular, we require you to opt in or opt out of the advertising cookies that we use.

To opt in or opt out, please visit the very bottom of this page and click on Update Privacy Settings. Alternatively, reload this page and the settings window will appear automatically.

Please note, for all other cookies, including functional and tracking cookies for example, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For more information about the cookies we use, please see our cookie policy.

For more information about advertising on this website, please see chapter 11.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the list in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not ordinarily transfer your personal data outside the European Economic Area (EEA).

As some of our External Third Parties are based outside the EEA, their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please check the glossary further down to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) is a bill that came into effect in California on January 1st 2020. It enhances privacy rights for California residents.

The data we have collected about you in the past 12 months

The data we collect about California residents is no different from the data we collect from other visitors around the world, which is: Identity Data, Contact Data, Technical Data, Usage Data, Marketing and Communications Data, Aggregated Data.

  • Please read chapter 2 for a description of each type of data
  • Please read chapter 3 for an explanation on how the data is collected
  • Please read chapter 4 for information on how we use each type of data

The data we have disclosed about you in the past 12 months

On this website, we serve advertisements. The revenue generated from displaying ads allows us to keep the website going and finance new content.

We and our advertising partners collect personal data when you visit our site. We, and our partners, use this data to tailor and deliver ads to you on our site, or to help tailor ads to you when you visit other sites. To tailor ads that may be more relevant to you, we and/or our partners may share the data we collect with third parties.

The data we and our advertising partners collect is: Usage Data, Technical Data. This includes for example the advertising identifier on your mobile device, or the IP address of your device.

The data is collected with the help of Targeting Cookies. They record your visit to our website, the pages you have visited and the links you have followed. You can read more about cookies in our cookie policy.

If you do not wish for us or our partners to disclose your personal data to third parties for advertising purposes, click on the “Do Not Sell My Personal Information” link at the bottom of the website (it is visible on every page). A pop-up window will open with further information and the possibility to opt-out from personalised advertisements.

Please note that although we will not sell your personal data after you click the link, we will continue to share some personal data with our partners for analytical, technical and security purposes.

To know more about advertising on this website, please check chapter 11.

How to contact us in connection to your CCPA rights

You can contact us by email address or via post. Please refer to our contact details in chapter 1.

Your rights as a California resident

You have the right to:

  • know what personal data is being collected about you
  • know whether your personal data is sold or disclosed, and to whom
  • say no to the sale of your personal data
  • request that a business delete any of your personal data in its records or any of its service providers’ records.
  • access your personal data
  • equal service and price when you exercise your privacy rights

Notice of non discrimination

If you wish to exercise your CCPA rights, rest assured that neither we nor our partners will discriminate against you in any way.

11. Mediavine Programmatic Advertising

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

12. Newsletter Sponsorships

We engage others to serve newsletter advertisements and perform related services across the web and in mobile applications. You can learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices.

Opting Out of Targeted Advertising, Sharing, and Sales.

We process personal information to understand and improve your experience with our Services and to serve you targeted advertisements. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under certain privacy laws. To opt out of preference-based advertising, use the form linked below. Note, this will not stop you from seeing sponsorships or advertisements in our newsletters, but those ads will be selected randomly rather than based on your known preferences.

https://convertk.it/opt-out-preference-based#newsletter_source=dailyitalianwords.com

13. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

External third parties

  • Service providers acting as processors based within the UK, EEA or US who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based within the UK who provide consultancy, banking, legal and insurance.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances..
  • ConvertKit, based in the US, who provides the newsletter platform.
  • Disqus, based in the US, who provide the commenting platform.
  • Mediavine, based in US, who provides our advert management services.
  • Mediavine Grow – this service used to allow users to save content from the Website. To utilize this service, you may sign up for an account which shall be governed by its own terms. Please refer to Mediavine’s privacy policy for further information.
  • Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics
  • Affiliates including Amazon, LingQ, etc. based either in the EEA or the US.
  • Vendors who are third-party advertisers, based within the EEA, who use cookies to collect non-sensitive data for the purpose of measurement and personalisation of advertisements. Visitors to this website are able to opt in or opt out of individual vendors and data collection.

To opt in or opt out, please visit the very bottom of this page and click on Update Privacy Settings. Alternatively, reload this page and the settings window will appear automatically.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.