Privacy Policy

Privacy policy on the processing of personal data. Effective as of 16th April 2025.

INTRODUCTION

This privacy policy is provided pursuant to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as well as the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and of the Privacy Code (Legislative Decree 30 June 2003 n. 196), where applicable. For users located in the European Union, data processing may also be subject to local privacy laws and interpretations of the GDPR by national Data Protection Authorities.

Data Controller: VISIBLE VOICES LIMITED, 33 Zealand Road - E3 5RA London (England), Email: hello@visible-voices.com

Site to which this privacy policy refers: https://www.visible-voices.com/ (Sito).

The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data.

The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.

On the Site you have the possibility to enter personal data of third parties. In this case you guarantee to have obtained the consent of these subjects to the insertion of these personal data. Therefore, you agree to indemnify and hold harmless the Data Controller from any liability.

Site registration

The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. in the case of making an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the legislation, to fulfill tax obligations). This treatment of personal data also includes the possibility of sending communications (e.g. tracking and order information) via automated tools such as SMS and/or WhatsApp.

The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations.

Apart from the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called "soft-spam". This means that limited to the email you provided in the context of a purchase through the Site, the Data Controller will process the email to allow direct offers from similar products/services, unless you object to such processing in the manner provided by this policy. The legal basis for processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications.

The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication.

Answering your requests

Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Marketing

Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis of this treatment is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send you newsletters.

These communications will be sent to your e-mail. We use Google services, such as Google Ads and Google Analytics, to personalize advertisements and enhance user experience. This includes the collection of personal data and cookies, used to show you ads that match your preferences. Upon consent, you will be asked to authorize the use of this data. More details on cookie usage and consent management can be found in this website's cookie policy.

Profiling

The Data Controller does not carry out "profiling" with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own products or third parties of your specific interest.

Data transfer

The Data Controller does not transfer your personal data to third parties.

Geolocalization

The Site does not implement tools to geolocate the user's IP address.

Curriculum Vitae

It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.

Booking Service

There are no third-party appointment booking systems active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the heading.

Photographs and videos

The Data Controller does not request the publication of photographs and/or videos of you. Therefore, your data will not be processed for these purposes.

Web scraping

The use of any automated process or system to access, acquire, copy, or monitor any part of our website, including, but not limited to, web scraping, crawling, or spidering techniques, is expressly prohibited. The Data Controller reserves the right to take all necessary measures, including legal action, to prevent and prosecute any unauthorised scraping activities.

By using the Site, the user or any third party agrees not to: (i) use automated systems, such as bots, scrapers, or spiders, to access or interact with the Site; (ii) collect content, data, or other information on the Site without express written permission; (iii) distribute, display, publish, or otherwise use content acquired through scraping techniques without consent.

Any breach of this clause will be considered a material breach of the terms of use of the Site and will result in appropriate action being taken, including the possible suspension of access to the Site and the taking of legal action to protect the interests of the Data Controller.

Communication of personal data

As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.

The "communication" of personal data to third parties is different from the "transfer" (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.

Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.

PRIVACY POLICY

Art. 1 Method of processing

1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality.

1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 Through the Site are not processed "special data". Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.

1.4 No judicial data is processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.

Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.

The Data Controller uses employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.

In its ordinary activity of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.

In order to send its communications, the Data Controller uses external companies in charge of sending this type of communication (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.

The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.

The Data Controller utilizes banking institutions and companies that manage national and international payment networks for online payments of products and services purchased through the Website.

The purchaser's personal data may be communicated to post offices, couriers or forwarding agents responsible for the delivery of the Products purchased through the Site.

The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Personal data retention

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

User data will be kept only for the time necessary to ensure the proper provision of the services offered through the Site.

For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove the Seller has performed its duties.

For customer care purposes, data will be deleted once the service is completed and, in any case, within a maximum period of 3 months after the last exchange of e-mails with the person concerned.

Invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit.

For marketing purposes, personal data will be kept until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email eventually viewed.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based in the United Kingdom, a country that has been deemed by the European Commission to offer an adequate level of protection for personal data, pursuant to the Adequacy Decision of 28 June 2021. Therefore, transfers of personal data from the European Union to the United Kingdom are considered lawful.

4.2 The Data Controller may also transfer your personal data to other non-EU/EEA countries that benefit from an adequacy decision issued by the European Commission. Such transfers are considered secure and compliant with applicable data protection legislation.

Your personal data may be transferred to the USA based on what is established by the adequacy decision of the European Commission. With this decision, the European Commission has determined that the USA provides personal data protection comparable to that offered by the European Union.

4.3 In the absence of an adequacy decision by the European Commission or the UK Government for certain third countries, your personal data may still be transferred outside the EU or the UK. In such cases, the Data Controller will implement appropriate safeguards under the EU GDPR and the UK GDPR. These safeguards may include the adoption of Standard Contractual Clauses (SCCs) approved by the European Commission, or the use of International Data Transfer Agreements (IDTA) or Addenda approved by the UK Information Commissioner's Office (ICO).

You are encouraged to check this section regularly for updates on international data transfers and the countries involved.

4.4 The Data Controller may specifically target its services to certain countries, including EU Member States. Where applicable, this may result in the application of local data protection laws in addition to those mentioned in the Preamble.

Upon request, the Data Controller will apply the most favourable applicable data protection law based on the user's country of residence.

Art. 5. Your rights

The Data Controller informs you that you have the right:

to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability

revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation

to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.

Art. 6. Amendments

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.