Google Lead Ads Privacy Policy

Alpha Palace Limited (hereinafter, “Alpha Palace”, “Data Controller” or “Company”), with registered office in 20 Oak View, Norton Street, Radford, Nottingham, Nottinghamshire, England, NG7 3NA as Data Controller, informs users, pursuant to UK regulation The Data Protection Act 2018 (hereinafter, “GDPR”) and the legislation, including national legislation, on the protection of personal data for time applicable (hereinafter, “Privacy Regulation”), that personal data (hereinafter, “Data”) relating to users of the Google Ads Lead Forms Extensions (hereinafter, “Data Subjects”) will be processed in the manner and for the purposes indicated in this policy.

1. DATA CONTROLLER

Alpha Palace Limited, with registered offices in 20 Oak View, Norton Street, Radford, Nottingham, Nottinghamshire, England, NG7 3NA, is the Data Controller.

2. TYPES OF PERSONAL DATA

The following Data are processed:

– Data provided voluntarily by the user, such as identification data, such as: first name, last name, email address, country, provided when providing their information in the form.

3. MINIMUM AGE

The protection of the safety and privacy of minors is very important to us. By registering in the Google “Lead Ads” campaign specific section, the Data Subject confirms that he/she is 18 years of age or, in any case, that he/she is not younger than the age indicated by the legislation of the country of residence that provides for other age limits.

Personal data provided by Data Subjects through the section are collected and processed for the following purposes and legal bases:

A. without prior consent for the purposes of the service and, in particular, to:

1. the pursuit of the Data Controller’s legitimate interest:

– preventing or detecting fraudulent activities or abuses harmful to the section, as well as exercising the rights of the Data Controller in court and manage the litigation: the interest of the Data Controller refers to the general, real and current interest not to suffer damages as a result of illegal conduct of others, as well as the right of action seen in The Data Protection Act 2018 and, as such, is socially recognised as prevailing over the interests of the data subject.

The fulfilment by the Data Controller of legal obligations, such as:

  • compliance with the obligations provided for by UK legislation or imposed by the competent relevant authorities.

B. Only by prior consent, provided by clicking on the “Submit” button, to marketing purposes, namely:

1. To contact the Data Subject as per their request, in order to provide all the information on offers and Alpha Palace’s campaigns, to the extent to enjoy other services which may help the Data Subject to discover Alpha Palace’s world and its commercial initiatives;

Deploy other activities which are functional to re-contact service.

NATURE OF SUBMISSION OF DATA

The provision of Data with respect to the purposes referred to in paragraph A) is mandatory and any refusal will make it impossible for the Company to carry out the contractual obligations undertaken and the execution of legal obligations, or to respond to your requests. As regards the purposes referred to in letter B) The provision of personal data is optional and their use is conditional on the release of an explicit consent by the Data Subject. Any refusal to grant consent has no effect other than that of not being able to inform Data Subjects about campaigns and initiatives of the Company via the contact options requested by the Data Subjects.

METHODS OF PROCESSING

The processing of Data of Data Subjects is carried out – with electronic modalities – by means of the operations of collection, registration, updating, organisation, conservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, cancellation and destruction of the Data. Data will be processed by the Company and its employees using computer systems (as well as manual means) in accordance with the principles of fairness, loyalty and transparency provided for by the applicable legislation on personal data protection and protecting the confidentiality of the Data Subject and his/her rights through the adoption of appropriate technical and organisational measures to ensure a level of security appropriate to the risk. Specific security measures are observed to prevent data loss, illegal or incorrect use and unauthorised access.

Data Retention

The Data Subject’s identification data will be processed by Alpha Palace for the time necessary to re-contact him/her or save/recover information. Subsequently, the Data will be kept for no longer than 7 years from collection and used exclusively to satisfy the legitimate interest of Alpha Palace in case of complaints and/or litigation.

SCOPE OF PROCESSING, COMMUNICATION, DISSEMINATION

Data processing is carried out by Alpha Palace’s internal staff appointed for this purpose as Data Processor or person in charge of processing. The Data collected for the execution of the above-mentioned purposes will also be processed by third parties appointed for this purpose as external Data Processors, or, as the case may be, communicated to the same as independent Data Controllers, and namely to:

RECIPIENT/SCOPE OF DATA COMMUNICATION WHAT WE MAY SHARE

Companies that are part of our corporate group for the purposes specified above Name, email address, residence.

Persons, companies, associations or professional firms providing assistance and consultancy to Alpha Palace, as well as accounting, administrative, legal, tax and financial matters Name, email address, residence, IP address.

Companies, bodies, associations that perform services related and instrumental to allow the navigation on the Website by the Data Subject, as well as couriers for the delivery of catalogues and / or products purchased, our online store, customer service, analysis and market research, management of payments by credit card, maintenance of computer systems. Name, email address, residence, IP address.

Public administrations for the performance of institutional functions within the limits established by law and regulations Name, email address, residence, IP address, payment information, preferences.

Furthermore, the Data may be made accessible, communicated and transferred to Public Bodies, Judicial Authorities, Police Bodies, who will process Data as independent controllers in order to follow up on requests for verification or where expressly provided for by law. 

The complete and updated list of the subjects that process Data as Data Processors and Independent Data Controller is available on request at Alpha Palace Limited, with registered office in 20 Oak View, Norton Street, Radford, Nottingham, Nottinghamshire, England, NG7 3NA. 

EXTRA- UK DATA TRANSFERS

The Company may transfer Data outside the United Kingdom. To this end, in accordance with privacy regulations, the Company assesses the impact of data transfers and adopts, if applicable, the most appropriate safeguards (for example, adequacy decisions or Standard Contractual Clauses).

11. DATA SUBJECTS’ RIGHTS

Data Subjects may exercise, in relation to the data processing described therein, the rights provided for by the The Data Protection Act 2018, including the right:

  • To receive confirmation of the existence of their personal data and access to their content (rights of access);
  • To update, modify and/or correct your personal data (right of rectification);
  • To request the deletion or limitation of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or otherwise processed (right to be forgotten and right to limitation);
  • To object the processing of personal data (right to object);
  • To withdraw consent, where given, without prejudice to the lawfulness of the processing based on the consent given before withdrawal;
  • To lodge a complaint with the Supervisory Authority in the event of breach of personal data protection regulations;
  • To receive a copy of the personal data provided to the Company in a structured, commonly used and machine-readable format, and request that such data be transmitted to another data controller (right to data portability).

Requests should be addressed to the Company by sending an e-mail message to privacy.alphapalace@gmail.com or by regular mail to the following address:

Kristin Shury Alpha Palace Limited 20 Oak View, Norton Street, Radford, Nottingham, England, NG7 3NA.

Users are invited to include in their requests all necessary information (such as name, e-mail and postal address, specific request and any other information) that the Company may need in order to respond to or otherwise manage the requests.

The Company will not discriminate against customers in the exercise of their rights.

POLICY UPDATE 

This Privacy Policy may be modified over time and we therefore invite users to periodically consult this page. To this end, the policy highlights the date of update.

Last Update: October 2022 Terms & Conditions

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PRIVACY NOTICE – The Data Protection Act 2018

Alpha Palace Limited (hereinafter, “Alpha Palace”, “Data Controller” or “Company”), with registered office in 20 Oak View, Norton Street, Radford, Nottingham, Nottinghamshire, England, NG7 3NA, as Data Controller, informs users, pursuant to The Data Protection Act 2018 (hereinafter, “GDPR”) and the legislation, including national legislation, on the protection of personal data for time applicable (hereinafter, “Privacy Regulation”), that personal data (hereinafter, “Data”) relating to users of the Website (hereinafter, “Data Subjects”) will be processed in the manner and for the purposes indicated in this policy.

THE DATA CONTROLLER

Alpha Palace is the Data Controller of the processing of Data collected through this Website;

Exclusively in relation to Facebook and Google Business Tools, (by way of example only, Facebook Cookies, and Google Cookies plug-ins and Pixels) Alpha Palace Limited and Facebook UK LTD, with registered office at 10 Brock Street, Regent’s Place, London, England, NW1 3FG (hereinafter “Facebook”) and Google UK Limited with registered office  at Belgrave House, 76 Buckingham Palace Road, London, SW1W 9TQ act as joint data controllers, on the basis of a specific Joint Controllership Agreement, in order to measure the level of interaction between the websites visited according to the preferences of the Data Subjects and to provide targeted advertising within the social network. Further information on how Facebook UK and Google UK processes Data, including the legal basis to which Facebook UK and Google UK refers and how to exercise your rights vis-à-vis Facebook UK and Google UK, can be found in Facebook UK’S Data Policy at Facebook Privacy Policy  https://www.facebook.com/about/privacy/previous and Google Privacy Policy. https://policies.google.com/privacy?hl=en 

THE DATA PROTECTION OFFICER

Pursuant to The Data Protection Act 2018 GDPR, the Data Controller has designated the Data Protection Officer, (hereinafter only “DPO”), who can be reached at the following address: DPO.alphapalace@gmail.com

Alpha Palace is the Data Controller of the processing of Data collected through this Website;

Exclusively in relation to Facebook Business Tools, (by way of example only, Facebook Cookies, plug-ins and Pixels) Alpha Palace Limited and Facebook UK LTD, with registered office at 10 Brock Street, Regent’s Place, London, England, NW1 3FG(hereinafter “Facebook”) act as joint data controllers, on the basis of a specific Joint Controllership Agreement, in order to measure the level of interaction between the websites visited according to the preferences of the Data Subjects and to provide targeted advertising within the social network. Further information on how Facebook UK processes Data, including the legal basis to which Facebook UK refers and how to exercise your rights vis-à-vis Facebook UK, can be found in Facebook UK’s Data Policy at Facebook Data Policy.

2. THE DATA PROTECTION OFFICER

Pursuant to The Data Protection Act 2018 GDPR, the Data Controller has designated the Data Protection Officer, (hereinafter only “DPO”), who can be reached at the following address: DPO.alphapalace@gmail.com

3. TYPE OF PERSONAL DATA

The following Data are processed:

Browsing data 

such as IP addresses or domain names of computers used by users who connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected to be associated with data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. These data are used only to obtain anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Website: to this effect, the data on web contacts could be kept in accordance with and limited to this purpose. Starting from the IP address and the domain name of the computers used, it will be possible, limited to the purpose of ascertaining responsibility, to trace back further identification data of the user (in particular, name, surname, e-mail address, telephone number, etc.);

Data freely provided by the user

such as identification data, like name, surname, e-mail, telephone number, tax code, etc.; any other data supplied, for example, when registering on the Website in the special section, or when filling in any data collection forms on the Website, or when requesting the supply/activation of a Alpha Palace service, such as the Newsletter Service;

Cookies for information on the cookies present on the Alpha Palace Website, please refer to the Cookie Policy.

MINIMUM AGE

The protection of the safety and privacy of minors is very important to us.  By registering on the Website in the appropriate section, as well as when filling out any data collection forms on the Website or when requesting the supply/registration to the Newsletter service, the Data Subject confirms that he/she is 18 years of age or, in any case, that he/she is not younger than the age indicated by the legislation of the country of residence that provides for other age limits.

PURPOSE OF PROCESSING

Personal data provided by Data Subjects through the Alpha Palace Website are collected and processed for the following purposes and legal bases:

A. without prior consent for the purposes of the service and, in particular, to:

1. the execution of the contract and/or pre-contractual commitments, namely: 

  • the use of the Website and any technical assistance;
  • the management of a contact request by the Data Subject;
  • Registration and access to the “My Alpha Palace reserved area by the Data Subject;
  • management of payments and/or finalisation of product purchase orders;

2. the fulfilment by the Data Controller of legal obligations, such as: 

  • compliance with the obligations provided for by laws, regulations or national and European legislation or imposed by the competent authorities;

3. the fulfilment by the Data Controller of legal obligations, such as: 

  • the management and maintenance of the Website: the interest of the Data Controller relates to the general interest of a company in guaranteeing business operations, also through the operation of the Website, and possible improvements in the service offered;
  • to carry out statistics – carried out by means of the analytical cookies described in the Cookie Policy of the Website, to which reference should be made – aimed at optimising and improving website navigation without identifying the user: the Data Controller’s interest lies in the general interest of a company to get acquainted with any critical points or suggestions for improving company operations;
  • preventing or detecting fraudulent activities or abuses harmful to the Website, as well as exercising the rights of the Data Controller in court and manage the litigation: the interest of the Data Controller refers to the general, real and current interest not to suffer damages as a result of illegal conduct of others, as well as the right of action of The Data Protection Act 2018 and, as such, is socially recognised as prevailing over the interests of the data subjects;
  • the sending to the data subject, when already our customer, of commercial communications relating to services and products of the Data Controller similar to those you have already used; the interest of the Data Controller refers to the general interest of a company to promote its services and is considered legitimate because it is in line with the reasonable expectations of the data subjects, taking into account the relationship between them and the Data Controller itself. Each email sent will allow the data subjects, by clicking on the appropriate link, to refuse further sending.

B. Only by prior consent to: 

1.Marketing purposes, in particular to: 

  • send promotional messages following the activation of the newsletter service, and commercial proposals (by mail, e-mail, mobile phone, sms, social media, social chat) relating to Alpha Palace products and services, for the sending of advertising material on Alpha Palace products and services, as well as catalogues and brochures or invitations to events, and in general commercial communications on Alpha Palace and its initiatives, as well as for carrying out market research and surveying the degree of customer satisfaction;

2. Profiling purposes, namely: 

  • To analyse the Data collected, including by automated means, and use it to process, communicate and allow Data Subject to take advantage of services, initiatives and personalised offers designed according to Data Subject’s interests, habits and propensity to consume. The Data Controller may also use the data of the Data Subject to create “clusters” (homogeneous groups made up of profiles that present a degree of correlation) depending on the habits and propensities of consumption in order to develop targeted digital campaigns in line with the preferences of individual users. The Data Controller may analyse the Data also to carry out surveys. To this end, we can also use dedicated automated software (e.g. CRM);

3. Purpose of using Facebook tools for measuring and analysing interactions with web pages visited by Data Subjects and providing targeted advertising on Facebook’s social network, specifically: 

  • the Company and Facebook UK LTD will process, as Joint Data Controllers as described in The Data Protection Act 2018 the data relating to the interactions with the websites visited by the Interested Parties through the use of Facebook Business Tools (by way of example only, Cookies, plug-ins and Facebook Pixel). In particular, the Alpha Palace Website uses social plug-ins. Social Plug-ins are special tools that make it possible to incorporate Social Network functions directly into the Website (e.g. the Facebook “like” function). When you visit a page on our Website and interact with the plug-in (e.g. by clicking the “Like” button) or leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform (in this case Facebook) and stored there. Further information on how Facebook UK processes the Data, including the legal basis to which Facebook UK refers and on how to exercise your rights towards Facebook UK, can be found in Facebook UK’s Data Policy at Facebook Data Policy.

4. Purpose of using Facebook services for measuring the interests and habits of the Website’s audience and providing targeted advertising on the Facebook social network: 

  • The Company will process Data relating to the interests, preferences and behaviour of the Data Subjects on the Website by means of the Facebook Custom Audience product, in order to provide targeted advertising within the Facebook social network. This processing involves, if consent is given by the Data Subjects, the communication of data to Facebook in order to proceed with the creation of custom audience lists and the subsequent delivery of targeted advertising. For this processing, Facebook acts as the Company’s data processor. For more information on the product, please consult Facebook’s Terms and Conditions at the following link Facebook Terms and Conditions.  https://en-gb.facebook.com/legal/terms