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Privacy Policy of simulead.com 
Simulead.com collects some Personal Data from its Users. 
 
Owner and Data Controller 
Simulead, Office 1710, Plot X2, Jumeirah Bay Tower, JLT, Dubai, UAE 
Owner contact email: [email protected] 
 
Types of Data collected 
Among the types of Personal Data that simulead.com collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; company name; country; email address; geographic position; Data communicated while using the service; phone number; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); date of birth; city; gender. 
 
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 simulead.com. 
Unless specified otherwise, all Data requested by simulead.com is mandatory and failure to provide this Data may make it impossible for simulead.com to provide its services. In cases where simulead.com 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 simulead.com or by the owners of third-party services used by simulead.com 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 simulead.com 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 simulead.com (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 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. 
 
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 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 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 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: Analytics, Contacting the User, Content commenting, Location-based interactions, Hosting and backend infrastructure, Interaction with external social networks and platforms, Interaction with live chat platforms, Registration and authentication, Registration and authentication provided directly by simulead.com, Traffic optimization and distribution, Displaying content from external platforms, Tag Management, Remarketing and behavioral targeting, Advertising and Managing data collection and online surveys. 
 
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: 
 
Advertising 
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on simulead.com, 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 or other Identifiers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside simulead.com. For more information, please check the privacy policies of the relevant services. 
 
In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page: https://optout.networkadvertising.org/?c=1. 
 
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. 
 
Facebook Audience Network (Facebook, Inc.) 
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook’s data policy: https://www.facebook.com/about/privacy/.  
  
Simulead.com may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings: https://www.facebook.com/ads/settings. 
  
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available. 
 
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/ – opt-out: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. Privacy Shield participant. 
 
Facebook Lookalike Audience (Facebook, Inc.) 
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of simulead.com or engagement with relevant content across the Facebook apps and services. 
 
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. 
  
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page: https://optout.aboutads.info/. 
 
Personal Data processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/ – opt-out: https://www.aboutads.info/choices/. Privacy Shield participant. 
 
 
 
 
Analytics 
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 Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of simulead.com, 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 processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://policies.google.com/privacy 
– opt-out: https://tools.google.com/dlpage/gaoptout?hl=en. Privacy Shield participant. 
 
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.) 
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on simulead.com. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network. 
 
Personal Data processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/. Privacy Shield participant. 
 
Facebook Analytics for Apps (Facebook, Inc.) 
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc. 
 
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/. Privacy Shield participant. 
 
Contacting the User 
Contact form (simulead.com) 
By filling in the contact form with their Data, the User authorizes simulead.com 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 processed: company name; country; email address; first name; last name. 
 
Mailing list or newsletter (simulead.com) 
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 simulead.com. Your email address might also be added to this list as a result of signing up to simulead.com or after making a purchase. 
 
Personal Data processed: email address; first name; last name. 
 
Content commenting 
Content commenting services allow Users to make and publish their comments on the contents of simulead.com. 
 
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. 
 
Comment system managed directly (simulead.com) 
Simulead.com has its own internal content comment system. 
 
Personal Data processed: first name; last name. 
 
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 processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/privacy/explanation. 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 simulead.com 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. 
 
Font Awesome (Fonticons, Inc. ) 
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows simulead.com to incorporate content of this kind on its pages. 
 
Personal Data processed: Usage Data. 
 
Place of processing: United States – privacy policy: https://fontawesome.com/privacy 
 
 
Google Fonts 
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location simulead.com is accessed from, that allows simulead.com to incorporate content of this kind on its pages. 
 
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – privacy policy: https://policies.google.com/privacy; Ireland – privacy policy: https://policies.google.com/privacy. Privacy Shield participant. 
 
Google Maps widget 
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on the location simulead.com is accessed from, that allows simulead.com to incorporate content of this kind on its pages. 
 
Personal Data processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://policies.google.com/privacy; Ireland – privacy policy: https://policies.google.com/privacy. Privacy Shield participant. 
 
Hosting and backend infrastructure 
This type of service has the purpose of hosting Data and files that enable simulead.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of simulead.com. 
 
Some services among those listed below, if any, may 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.) 
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc. 
 
Personal Data processed: various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – privacy policy: https://aws.amazon.com/compliance/data-privacy-faq/. 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 simulead.com. 
 
The interaction and information obtained through simulead.com 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 simulead.com isn’t being connected back to the User’s profile. 
 
AddThis (Oracle Corporation) 
AddThis is a service provided by Oracle Corporation, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of simulead.com. 
 
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed. 
 
Personal Data processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.oracle.com/legal/privacy/addthis-privacy-policy.html 
 
 
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 processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/privacy/explanation. Privacy Shield participant. 
 
Interaction with live chat platforms 
This type of service allows Users to interact with third-party live chat platforms directly from the pages of simulead.com, for contacting and being contacted by simulead.com support service. 
 
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged. 
 
Facebook Messenger Customer Chat (Facebook, Inc.) 
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc. 
 
Personal Data processed: Cookies; Data communicated while using the service; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/. Privacy Shield participant. 
 
Location-based interactions 
Geolocation (simulead.com) 
Simulead.com 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 authorization has been provided, the User’s location data may be tracked by simulead.com. 
 
Personal Data processed: geographic position. 
 
Non-continuous geolocation (simulead.com) 
Simulead.com 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 authorization has been provided, the User’s location data may be tracked by simulead.com. 
 
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 processed: geographic position. 
 
Managing data collection and online servers 
This type of service allows simulead.com to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users. 
 
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form. 
 
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing. 
 
Facebook lead ads (Facebook, Inc.) 
Facebook lead ads is an advertising and data collection service provided by Facebook, Inc. that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information. 
  
Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided. 
  
Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy. 
 
Personal Data processed: city; date of birth; email address; first name; gender; last name. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/ – opt-out: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. Privacy Shield participant. 
 
Registration and authentication 
By registering or authenticating, Users allow simulead.com 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, simulead.com will be able to access some Data, stored by these third-party services, for registration or identification purposes. 
 
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service. 
 
Facebook Authentication (Facebook, Inc.) 
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. 
 
Personal Data processed: various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/help/405977429438260. Privacy Shield participant. 
 
Google OAuth 
Google OAuth is a registration and authentication service provided by Google LLC or by  
 
Google Ireland Limited, depending on the location simulead.com is accessed from, and is connected to the Google network. 
 
Personal Data processed: various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – privacy policy: https://policies.google.com/privacy; Ireland – privacy policy: https://policies.google.com/privacy. Privacy Shield participant. 
 
Registration and authentication provided directly by simulead.com 
By registering or authenticating, Users allow simulead.com to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users. 
 
Direct registration (simulead.com) 
The User registers by filling out the registration form and providing the Personal Data directly to simulead.com. 
 
Personal Data processed: email address; first name; last name; phone number. 
 
 
 
Remarketing and behavioural targeting 
This type of service allows simulead.com and its partners to inform, optimize and serve advertising based on past use of simulead.com by the User. 
 
This activity is facilitated by tracking Usage Data and by using Cookies and other Identifiers 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. 
 
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising opt-out page: https://optout.networkadvertising.org/?c=1 
 
 
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. 
 
Facebook Remarketing (Facebook, Inc.) 
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of simulead.com with the Facebook advertising network. 
 
Personal Data processed: Cookies; Usage Data. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/– opt-out: https://www.aboutads.info/choices/. Privacy Shield participant. 
 
Facebook Custom Audience (Facebook, Inc.) 
Facebook Custom Audience is a remarketing and behavioral targeting service provided by  
 
Facebook, Inc. that connects the activity of simulead.com with the Facebook advertising network. 
  
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page: https://www.aboutads.info/choices/ 
 
Personal Data processed: Cookies; email address. 
 
Place of processing: United States – privacy policy: https://www.facebook.com/about/privacy/ 
 – opt-out: https://www.aboutads.info/choices/. Privacy Shield participant. 
 
Tag management 
This type of service helps the Owner to manage the tags or scripts needed on simulead.com in a centralized fashion. 
 
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data. 
 
Google Tag Manager 
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on the location simulead.com is accessed from. 
 
Personal Data processed: Usage Data. 
 
Place of processing: United States – privacy policy: https://policies.google.com/privacy; Ireland – privacy policy: https://policies.google.com/privacy. Privacy Shield participant. 
 
 
Traffic optimization and distribution 
This type of service allows simulead.com to distribute their content using servers located across different countries and to optimize their performance. 
 
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between simulead.com and the User's browser. 
 
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred. 
 
Cloudflare (Cloudflare Inc.) 
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. 
 
The way Cloudflare is integrated means that it filters all the traffic through simulead.com, i.e., communication between simulead.com and the User's browser, while also allowing analytical data from simulead.com to be collected. 
 
Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service. 
 
Place of processing: United States – https://www.cloudflare.com/privacypolicy/ 
 
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. 
 
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 simulead.com 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, simulead.com 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, simulead.com and any third-party services may collect files that record interaction with simulead.com (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 
Simulead.com does not support “Do Not Track” requests. 
To determine whether any of the third-party services it uses honor 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 notifying its Users on this page and possibly within simulead.com 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 simulead.com (or third-party services employed in simulead.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use simulead.com, 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 simulead.com 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 simulead.com. The Data Controller, unless otherwise specified, is the Owner of simulead.com. 
 
simulead.com (or this Application) 
The means by which the Personal Data of the User is collected and processed. 
 
Service 
The service provided by simulead.com 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 simulead.com, if not stated otherwise within this document. 
 
 
 
 
 
 
Latest update: April 20, 2020 
 

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