Privacy Policy

Last update: 27  november 2019

 

Thanks for visiting Pocketfolio! Pocketfolio (“Pocketfolio”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.

By using any of Pocketfolio’s Services, you confirm you have agreed to the Terms of Service and read and understood this Privacy Policy and our Cookie Policy.

1. What This Privacy Notice Covers

The purpose of this Privacy Notice is to explain how we secure, share, and use personal information that we collect and receive from you through our website (https://pocketfolio.net), website hosting and design services, communication tools, mobile applications, app marketplace, ecommerce tools, and other services (collectively, the “Service”).  If you have any questions or concerns regarding this Privacy Notice or our practices, please see the “Contact Us” section below.

  • For Users Outside the European Union: for users located outside of the European Union, by submitting any personal information through our website or otherwise through our Service, you agree to the terms of this Privacy Notice and you expressly consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Notice.
  • For all users: we may use information shared with us for any legal purpose, including to run and improve our Service and for marketing purposes, but in each case solely in accordance with applicable law, the scope of your consent to use such information (if applicable) and, where Pocketfolio acts as a data processor for a data controller, solely on the basis of instructions from such data controller. For example, with respect to some parts of our Service, such as our e-commerce platform, our user is the data controller and Pocketfolio is a data processor.  As a data processor, Pocketfolio does not have a direct relationship with the person whose personal information we collect and process at the direction of our user (i.e. the data controller).  If you are a customer of one of these users and no longer want to be contacted by that user or want to access and change the personal information we collect and process as a data processor, please contact the user you interacted with directly.

2. Personal Information we collect

We may collect various personal information regarding you, your device, or your use of our websites,  as further described below:

  • Personal Information provided by you.
    We collect your personal information (such as email address first name and last name) when you:
    – Register an account with us.
    – Using our customer support service.
    – Subscribe for a premium license.
    – Subscribe to our newsletter or enter our promotions.
    – Post content on a Pocketfolio Website.
    We may also collect other information you submit to us directly or through Third Party Services. We use this personal information in order to provide you with our Service, to respond to billing inquiries, and keep you updated with news about Pocketfolio, the Service, and our partners in accordance with your consent preferences as applicable.
  • Personal information obtained from your use of our Services.
    When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information.
    If you are an End User of our Users’ sites, we also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).
  • We collect information about your use our services and your activities with your websites created in Pocketfolio
    When you are logged-in in Pocketfolio we use an Activity Log Software to monitor and collect informations about your activity and interaction with our services, especially when you perform any type of activity in any of the website created by you in Pocketfolio. We use this informations to improve our services, offer you a better experience and improve our security systems.
  • Billing Information.
    If you sign up for a Pocketfolio Subscription Plan or purchase another paid service, we require your billing information in order to process the transaction. Billing information includes your name, email, address, business informations, vat or tax id number, PayPal email address, and other information necessary to process the transaction. Pocketfolio does not require or store your credit card number or CVV2. If you sign up for Paid Services, we obtain limited information about your payment from our payment processor, such as transaction id and email address used for the transaction. Currently, our payment processor is Paypal. Paypal uses and processes your complete payment information in accordance with Paypal’s privacy policy.
  • Cookies and Other Tracking Technologies.
    Some informations are collected automatically using cookies and similar technologies when you use our Services and our Users’ sites. We let our Users control what cookies and similar technologies are used through their sites (except those we need to use to provide the Services properly, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.
  • Sensitive Consumer Information.
    Pocketfolio does not collect or use “sensitive consumer information” and does not offer or sell to any third party any data based on sensitive consumer information.  For purposes of this Privacy Notice, “Sensitive consumer information” includes social security numbers or other government-issued identifiers, insurance plan numbers, financial account numbers, and precise information about past, present, or potential future health or medical conditions or treatments, including genetic, biometric, genomic and family medical history nor does it include racial or ethnic origin information, information about sexual orientation, criminal records or trade union membership information. Pocketfolio maintains internal policies and procedures designed to safeguard against the collection or use of such information.

We do not collect or use “sensitive consumer information” and do not offer or sell to any third party any data based on sensitive consumer information.

3. How we use your personal information

We use the personal information we obtain about you to:

  • Provision of the Services. Create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.

  • Communicating with you. Communicate with you, including by sending you emails about your transactions and Service-related announcements.

  • Surveys and contests. Administer surveys, contests and other promotions.

  • Promotion. Promote our Services and send you tailored marketing communications about products, services, offers, programs and promotions of Pocketfolio and our partners and measure the success of those campaigns. For example, we may send different marketing communications to you based on your subscription plan or what we think may interest you based on other information we hold about you.

  • Advertising. Analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you. For example, we may decide not to advertise our Services to you on a social media site if you already signed up for Paid Services or we may choose to serve you a particular advertisement based on your subscription plan or what we think may interest you based on other information we hold about you.

  • Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering which of Your Sites you most recently edited.

  • Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.

  • Security. Ensure the security and integrity of our Services.

  • Third party relationships. Manage our vendor and partner relationships.

  • Enforcement. Enforce our Terms of Service and other legal terms and policies.

  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).

  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

4. Who we share your personal information

Pocketfolio does not share personal information we learn about you from your use of the Service with others except as described in this Privacy Notice.

  • Completion of Transactions
    Pocketfolio may share your personal information on a secured basis where it is necessary to complete a transaction; to operate, improve, or communicate to you about the Service; to detect fraud or compliance with export regulations; or to do something that you have asked us to do. We use other third parties such as payment processors to bill you for goods and services. These third parties are authorized to use your personal information only as necessary to provide these services to us and are prohibited from using your personal information for promotional purposes.
  • Research, Promotions, and Contests
    From time to time, Pocketfolio or a partner may sponsor a research panel, promotion, or contest on Pocketfolio. You may be asked to provide personal information including name, email address, or to answer questions in order to participate. This information will be used strictly for purposes of the research panel, promotion, or contest administration and fulfillment, as well as for internal business purposes.
  • Third Party Marketing
    Pocketfolio may share anonymized and/or aggregated information with third parties for their marketing, advertising, promotion, or other uses. In addition, from time to time we may share your personal information with third parties who want to promote goods and/or services that we think would be of interest to you. If you are located in the EU, we will only share your personal information for any marketing purposes where you have consented to this after being provided with information on the concerned third parties or where it is otherwise lawful to do so. If you want us to stop sharing your contact information with third parties, you may notify us through our contact page.
  • Publicly Accessible Information
    If you post personal information online that is accessible to the public, like blogs, you may receive unsolicited messages from other parties in return. Any information you provide in these areas may be read, collected, and used by others who access them. To have your personal information removed from our blog or community forum, submit a request through our contact page. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
  • Lawful disclosure
    Pocketfolio may disclose personal information about you in response to lawful requests by public authorities, including but not limited to national security or law enforcement requests. We may also disclose your personal information as required by law, such as to respond to subpoenas, court orders, or similar legal processes, to establish or exercise our legal rights or, defend against legal claims, or if in our judgment in such circumstances disclosure is required or appropriate. If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our various terms of use, or as otherwise required by law.

5. How we protect your personal information

We take reasonable steps to put in place appropriate physical, electronic, and procedural safeguards to protect the integrity and security of personal information about you and to prevent unauthorized or unlawful processing of personal information and the accidental loss, destruction, or damage to personal information.  These measures include internal reviews of our data collection, storage and processing practices and security measures (Strong password protection and in certain areas industry standard SSL-encryption to protect data transmissions), as well as physical security measures to guard against unauthorized access to systems where we store data.

However, data transmissions over the Internet and methods of electronic storage are not 100% secure. Consequently, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk.

If Pocketfolio learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our applicable web sites if a security breach occurs. If this happens, you will need a web browser enabling you to view the applicable web sites. In these circumstances, we may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) submit a request through our help center.

6. How we retain your personal information

We retain personal information regarding you or your use of the Services for as long as your Account is active or for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active, while the period for which we keep a support message is based on how long has passed since the last submission in the thread.

As Users may have a seasonal site or come back to us after an Account becomes inactive, we don’t immediately delete your personal information when your trial expires or you cancel all Paid Services. Instead, we keep your personal information for a reasonable period of time, so it will be there for you if you come back.

You may delete your Account by contacting us through our official contact page and Pocketfolio will delete the personal information it holds about you (unless we need to retain it for the purposes set out in this Privacy Policy).

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

7. Your Privacy Rights

  • Pocketfolio as Data Controller
    Upon request, we will provide you with information about whether we hold or process your personal information on behalf of third parties. You can access and edit your account information with Pocketfolio at any time by logging into your account. You can also contact us via our official contact page, and we will respond as soon as possible, but at most within 30 days. You can delete your applicable account by submitting a request through our official contact page; however, some personal information, primarily your contact information, may remain in our records to the extent necessary to protect our legal interests or document compliance with regulatory requirements, in each case solely to the extent permitted by applicable law. If your personal information changes, or if you no longer wish to use our Service, you may correct, update, or delete such information by making the change on your user account page, or by submitting a request through our our official contact page.
  • Pocketfolio as Data Processor
    Pocketfolio acknowledges you have the right to access and change the personal information we collect and process as a data processor.  An individual who seeks to access or to correct, amend, or delete personal information should direct their request to the Pocketfolio user who is the data controller, and not to Pocketfolio directly. If the data controller requests Pocketfolio remove personal information we will respond within a reasonable timeframe.
  • Users in the European Union only
    Under EU Regulation 2016/679 of the European Parliament and the Council; the General Data Protection Regulation (“GDPR”), you have a number of rights when it comes to your personal information. Further information and advice about your rights can be obtained from the data protection regulator in your country of residence within the EU. You can exercise any of these rights by contacting us through our official contact page or the details in the contact us section below.
  • The right to be informed
    You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
  • The right of access
    You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. You can do this by writing us on the email address below.
  • The right to rectification
    You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in personal information that we hold by writing us on the email address below.
  • The right to erasure
    This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  • The right to restrict processing
    You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
  • The right to data portability
    You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.
  • The right to object to processing
    You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services we provide which we think may be of interest to you or being contacted with varying potential opportunities). You may change your preferences regarding email communications by visiting one of our preference centers listed below.
  • The right to lodge a complaint
    You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
  • The right to withdraw consent
    If you have given your consent to anything we do with your personal data (i.e we rely on consent as a legal basis for processing your personal information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal information at any time.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

8. Data transfer

Where required, we may transfer your personal information to our servers located outside the country in which you live (In particular, if you are an Extra-EU resident, your personal information is automatically transferred to us in the E.U). Laws of other countries on personal information can sometimes be different from those in your country of residence. We will only transfer data where it is lawful to do so.  Where your personal information is transferred outside its country of origin, we ensure security measures and appropriate safeguards are put in place to protect your personal information and ensure that all transfers of your personal information comply with applicable data protection law, and are carried out in accordance with Pocketfolio’s instructions.

9. End Users’ personal information

Our customers who have created a site using Pocketfolio are responsible for what they do with the personal information they collect, directly or throughPocketfolio, about their End Users.  This section is directed to such customers.

  • Your relationship with End Users
    If you’re one of our Users, you will collect personal information about your End Users. For example, during checkout you may ask your End Users to provide their name, address, email address and payment information so that you can complete their orders. You may also use cookies and similar technologies to analyze usage and other trends.
    You’re solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them from us or using Pocketfolio functionality or cookies or similar technologies.
    You must publish your own privacy and cookie policy and comply with them.
    We’re not liable for your relationship with your End Users or how you collect and use personal information about them (even if you collect it from us or using Pocketfolio functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.
  • End User payment information
    Your End Users’ payment information may be processed via third party eCommerce Payment Processors with which you integrate your Account, in accordance with such eCommerce Payment Processors’ terms and policies. We transmit your End Users’ complete payment information when they initially provide or update it only so that we can pass it along to the eCommerce Payment Processors you agree to use. We don’t collect or store your End Users’ payment information.

10. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).
We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

11. How to contact us

Pocketfolio is owned and managed in Italy by Virgodesign di Virgilio Ragazzi. If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please contact us through our official contact page, or write to us at the address below:

Virgodesign di Virgilio Ragazzi
Via Pietra dell’Ova 416
95030 – Tremestieri Etneo (CT)
Italy