(ART. 13 e14 REG. EU 2016/679)

Below we wish to inform you of which of your data we collect when you use our website and how these are used. If our website contains links leading to another provider's site, our privacy policy is not applicable to the website on which you will be redirected. By accepting this privacy policy, you accept the collection, processing and use of your personal data by imanager srl, based on data protection legislation / General data protection regulation (GDPR) and the following terms and conditions. Please take all the time you need to read the following carefully.


The data controller is the subject responsible for the processing of your personal data and determines the purposes and means of processing your data. In this case, the Data Controller is: Imanager SRL - Via Santa Maria Valle 3, Milan 20123, registered with the Milan Chamber of Commerce Monza Brianza Lodi, VAT number: 10275570967. Email address of the holder: If you wish to oppose the collection, processing or use of your personal data by the site in charge in accordance with data protection legislation, you can express your opposition to us by e-mail to the address indicated above. However, this may result in the service being no longer usable.

Types of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies, Usage data, name, surname, date of birth, telephone number, address, city, email, Email, sex, company name and geographical location.
Full details of each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected. The Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation. Users who have doubts about which data are mandatory, are encouraged to contact the owner. Any use of Cookies - or other tracking tools - by this Application or third party service providers used by this Application, unless otherwise stated, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy. The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any responsibility towards third parties.

Mode and place of processing of the collected Data

Methods of treatment The Data Controller adopts the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and / or telematic tools, with organizational methods and with logics strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of managers can always be requested from the Data Controller.

Legal basis of the processing

The Owner processes Personal Data relating to the User if one of the following conditions exists: the User has given consent for one or more specific purposes;

Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User's consent or another legal basis specified below, as long as the User does not object ("out-put") to such treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data; • the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures; • processing is necessary to fulfill a legal obligation to which the Owner is subject; • processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller; • processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties. It is in any case always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.


The Data are processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner. The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section on the details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. Should one of the transfers described above take place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated at the opening.

Period of conservation

The Data is processed and stored for the time required for the purposes for which it was collected. It will be our commitment to cancel them and provide for the destruction after 24 months from the consent, except for agreements expressly accepted by the User at the time of consent and except as provided below.

• The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the processing is based on the User's consent, the Owner can keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep the Personal Data for a longer period in accordance with a legal obligation or by order of an authority. At the end of the storage period the Personal Data will be deleted. Therefore, upon expiration of this term the right of access, cancellation, rectification and the right to the portability of the Data can no longer be exercised.

Purposes of the processing of the collected data

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, Access to accounts on third party services, Contacting the User, Business affiliation, Contact management and sending messages, Management of Users database, Payment management, Tag management, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Registration and authentication, Remarketing and behavioral targeting and Display of content from external platforms. To obtain further detailed information on the purposes of the processing and on the Personal Data that are concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Facebook permissions required by this Application

This Application may require certain Facebook permissions that allow it to perform actions with the User's Facebook account and to collect information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc. For more information on the permissions that follow, refer to the documentation of the Facebook permissions and the privacy policy of Facebook. The required permits are as follows:

Basic information

The basic information of the User registered on Facebook that normally includes the following Data: id, name, image, gender and language of localization and, in some cases, the "Friends" of Facebook. If the User has made additional data publicly available, they will be available.


Provides access to the User's primary email address. Details on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:
• Access to accounts on third party services
• Business affiliation
• Contact the user
• Contact management and sending messages
• User database management
• Payment management
• Tag management
• Hosting and backend infrastructure
• Interaction with live chat platforms
• Location-based interactions
• Registration and authentication
• Remarketing and behavioral targeting
• Statistics
• Display of content from external platforms
• Further information on Personal Data
• Push notifications
• Sale of goods and services online

User Rights

You have the right to receive free clear information from iManager srl regarding the personal data we have stored about you;

Interested parties may exercise certain rights with reference to the Data processed by the Owner. In particular, the User has the right to:

- Accessing Your Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
- Obtain the treatment limitation from the holder. When certain conditions are met, the User can request the limitation of the processing of his / her Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
- Oppose the processing of your data. You may object to the processing of your data when it takes place on a legal basis other than consent. Further details on the opposition right are indicated in the section below.
- Check and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.
- Obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of his / her Data by the Owner.
- Obtain data portability. The User has the right to receive his / her Data in structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the Data is processed by automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
- Withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed, without affecting the lawfulness of the treatment based on the consent acquired before the revocation;
- Make a complaint. The User has the right to lodge a complaint with the Italian Data Protection Authority.

It is also possible to send the complaint to the supervisory authority of your place of habitual residence or work. If you wish to exercise your rights as a subject affected by the processing, please do not hesitate to contact us pursuant to the contact information provided above.

Personal data is information from which we can directly or indirectly identify your person, it is data such as name and surname, address, telephone number, date of birth, data relating to your location or e-mail address.

Please provide us with only the information we need strictly.

We wish to provide you with a good overview of the various profiles related to the processing of your data and we have chosen to illustrate them with tables. We believe that this will allow us to provide you with information in a transparent, understandable and easily accessible form as well as in clear and simple language.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuing a legitimate interest of the Data Controller, Users have the right to object to processing for reasons connected to their particular situation. Users are reminded that, if their Data is processed for direct marketing purposes, they may oppose the processing without giving any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise the User's rights, Users can address a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cookie Policy

This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.
Further information on treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or of the connected Services by the User. The User declares to be aware that the Owner may be required to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Application could provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, that is files that record the interactions and that may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to "Do Not Track" requests

This application does not support "Do Not Track" requests. To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the details of contact of which the Holder is in possession. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom. If the changes involve processing whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.


In addition to the purposes and legal bases mentioned above, we also process your personal data on the basis of the so-called legitimate interest. One of the main legitimate interests is, for example, the processing of personal data within a group of companies, treatments made necessary for network and information security or in direct marketing activities. We use your personal data to pursue our legitimate interests, provided that your rights and freedoms do not prevail. To reconcile our interests with your rights, we have introduced appropriate control mechanisms. These treatments include:

Process based on legitimate interest Explanation Advertising

We will send you emails to offer you coupons, discounts and promotions, conduct opinion polls and surveys to improve our service. You may oppose further processing of data for advertising purposes to any e-mail you receive. Of course, if you wish to oppose the processing of your data for advertising purposes or for further information on this question you can also contact our data protection manager directly at:

Email marketing

We want to avoid generic newsletters and uncontrolled marketing measures. Therefore, we select the offers that suit your interests and contact you if we believe the information may be of interest to you. You may oppose further processing of data for advertising purposes with any e-mail. Of course, if you wish to oppose the processing of your data for advertising purposes or for further information on this question you can also contact our data protection manager directly at:

Measurement data

In order to improve our services we collect various measurement data, which we cannot trace back to you or a profile. This helps us optimize our advertisements.

Merger and acquisition, change of ownership

We also wish to inform you that in the event of a merger or acquisition by another company, we will provide the information to that company. Of course, we will require that company to comply with legal data protection regulations.

Other information

We will obviously be happy if you want to voluntarily share with us information that goes beyond the strictly mandatory. In this way, we can continue to improve our service. This is data that you voluntarily provide when you use our website, our apps, but also information from other sources such as social media or other (public) databases (for example User-ID of other platforms).

Quality assessment

To offer you better services, we regularly evaluate the success or potential causes of marketing failure. For this reason we analyze for example if our newsletters are open and even if the contents are clicked.