Privacy Policy of WillBox.me


WillBox.me collects some Personal Data from its Users.

Data Controller and Owner

Fermi S.p.a. – Foro Buonaparte, 12 – 20121 Milano (Italia),
[email protected]

Types of Data collected

Among the types of Personal Data that WillBox.me collects, by itself or through third parties, there are: Phone number, Email address, Password, Cookie, Usage data, First Name and Last Name.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when using WillBox.me.
Any use of Cookies – or of other tracking tools – by WillBox.me or by the owners of third party services used by WillBox.me, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.
Failure to provide certain Personal Data may make it impossible for WillBox.me to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through WillBox.me 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 Data Controller processes the Data of Users in a proper manner and shall take 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 Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (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 Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Registration and authentication, Analytics, Interaction with live chat platforms, Contacting the User, Access to third party services’ accounts, Managing contacts and sending messages, Remarketing and Behavioral Targeting, Infrastructure monitoring, Traffic optimization and distribution, Social features and Handling payments.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Access to third party services’ accounts

    These services allow WillBox.me to access Data from your account on a third party service and perform actions with it.
    These services are not activated automatically, but require explicit authorization by the User.

    Access to the Google Drive account (Google)

    This service allows WillBox.me to connect with the User’s account on Google Drive, provided by Google, Inc.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

    Access to the Dropbox account (Dropbox, Inc.)

    This service allows WillBox.me to connect with the User’s account on Dropbox, provided by Dropbox, Inc.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

  • 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)

    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of WillBox.me, 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 collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy – Opt Out

    Google AdWords conversion tracking (Google)

    Google AdWords conversion tracking is an analytics service provided by Google, Inc. that connects data from the Google AdWords advertising network with actions performed on WillBox.me.

    Personal Data collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy

    Facebook Ads conversion tracking (Facebook)

    Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on WillBox.me.

    Personal Data collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy

  • Contacting the User

    Mailing List or Newsletter (WillBox.me)

    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 WillBox.me. Your email address might also be added to this list as a result of signing up to WillBox.me or after making a purchase.

    Personal Data collected: Email address.

    Contact form (WillBox.me)

    By filling in the contact form with their Data, the User authorizes WillBox.me 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 collected: Email address, First Name and Last Name.

    Phone contact (WillBox.me)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to WillBox.me, as well as for fulfilling support requests.

    Personal Data collected: Phone number.

  • Handling payments

    Payment processing services enable WillBox.me to process payments by credit card, bank transfer or other means. To ensure greater security, WillBox.me shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
    Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

    Stripe (Stripe Inc)

    Stripe is a payment service provided by Stripe Inc.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

  • Infrastructure monitoring

    These services allow WillBox.me to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of WillBox.me.

    New Relic (New Relic)

    New Relic is a monitoring service provided by New Relic Inc.
    The way New Relic is integrated means that it filters all traffic of WillBox.me, i.e., communication between the Application and the User’s browser or device, while also allowing analytical data on WillBox.me to be collected.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

    Pingdom (Pingdom AB)

    Pingdom is a monitoring service provided by Pingdom AB.

    Personal Data collected: Cookie and Usage data.

    Place of processing : Sweden – Privacy Policy

  • Interaction with live chat platforms

    These services allow Users to interact with third party live chat platforms directly from the pages of WillBox.me, for contacting and being contacted by WillBox.me 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.

    Zopim Widget (Zopim Technologies Pte Ltd)

    The Zopim Widget is a service for interacting with the Zopim live chat platform provided by Zopim Technologies Pte Ltd.

    Personal Data collected: Cookie and Usage data.

    Place of processing : Singapore – Privacy Policy

  • Managing contacts and sending messages

    These services make it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    Mailchimp (Mailchimp)

    Mailchimp is an email address management and message sending service provided by Mailchimp Inc.

    Personal Data collected: Email address.

    Place of processing : USA – Privacy Policy

    Twilio (Twilio, Inc.)

    Twilio is a phone numbers management and communication service provided by Twilio, Inc.

    Personal Data collected: Phone number.

    Place of processing : USA – Privacy Policy

  • Registration and authentication

    By registering or authenticating, Users allow WillBox.me 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, WillBox.me will be able to access some Data, stored by these third party services, for registration or identification purposes.

    Direct registration (WillBox.me)

    The User registers by filling out the registration form and providing the Personal Data directly to WillBox.me.

    Personal Data collected: Email address, Password and Phone number.

    OneDrive OAuth (Microsoft Corporation)

    OneDrive OAuth is a registration and authentication service provided by Microsoft Corporation and is connected to the OneDrive network.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

  • Remarketing and Behavioral Targeting

    These services allow WillBox.me and its partners to inform, optimize and serve advertising based on past use of WillBox.me by the User.
    This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

    AdWords Remarketing (Google)

    AdWords Remarketing is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the activity of WillBox.me with the Adwords advertising network and the Doubleclick Cookie.

    Personal Data collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy – Opt Out

    Facebook Remarketing (Facebook)

    Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook Inc. that connects the activity of WillBox.me with the Facebook advertising network.

    Personal Data collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy

  • Social features

    Inviting and suggesting friends (WillBox.me)

    WillBox.me may use the Personal Data provided to allow Users to invite their friends – for example through the address book, if access has been provided – and to suggest friends or connections inside it.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

  • Traffic optimization and distribution

    These services allow WillBox.me 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 WillBox.me 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 User are transferred.

    CloudFlare (Cloudflare)

    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 WillBox.me, i.e., communication between WillBox.me and the User’s browser, while also allowing analytical data from WillBox.me to be collected.

    Personal Data collected: Various types of Data as specified in the privacy policy of the service.

    Place of processing : USA – Privacy Policy

  • Heat mapping

    Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.

    Inspectlet (Inspectlet Inc.)

    Inspectlet is a heat mapping service provided by Inspectlet Inc.

    Personal Data collected: Cookie and Usage data.

    Place of processing : USA – Privacy Policy

Cookie Policy

Willbox uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

Further information about Personal Data

  • Content stored on WillBox.me

    All content uploaded and stored by Users on their WillBox.me account are encrypted and can not be accessed by any person, except for the User and the recipient of the access keys designated by the User, who can access it, however, only at a time when the User has passed away. The Owner presumes the death of the User, when they did not respond to LifeCheck according to the instructions specified in the Terms and Conditions of WillBox.me.

  • Third party data

    WillBox.me requires that Users specify one or more third parties, which, at the time of the passing of the User, will have access to the User’s WillBox.me account. The User must provide their name, surname and email address of the third parties designated to receive the keys. Such data will be used by the Owner for the sole purpose of contacting the third parties indicated by the User via email for the communication of said access authorization.

  • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.

    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by WillBox.me depends on the payment system used.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of WillBox.me or the related services.
The User declares to be aware that the Data Controller 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, WillBox.me 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, WillBox.me and any third party services may collect files that record interaction with WillBox.me (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

WillBox.me 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 Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using WillBox.me and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from WillBox.me (or third party services employed in WillBox.me ), which can include: the IP addresses or domain names of the computers utilized by the Users who use WillBox.me, 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 WillBox.me, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of WillBox.me. The Data Controller, unless otherwise specified, is the Owner of WillBox.me.

WillBox.me

The hardware or software tool by which the Personal Data of the User is collected.

Cookie

Small piece of data stored in the User’s device.


Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to WillBox.me.

Latest update: March 27, 2015