Last updated: November 16, 2021
We respect your privacy and want you to be familiar with how we collect, use and disclose information.
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our site; you can be assured that it will only be used in accordance with this policy.
This policy also tells you how We comply with the General Data Protection Regulation (“GDPR”) ((EU) 2016/679), the UK GDPR and the UK's Data Protection Act 2018. You can read more about the GDPR here: https://www.eugdpr.org/.
Important information and who we are
The Company is a data controller under the GDPR. The website provider, Aruba S.p.A., who is processing data under instructions from us, is responsible for this website.
You have the right to make a complaint about your personal data at any time to the relevant supervisory authority and this link will give you an overview of all national data protection authorities in Europe http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.
Our contact details are:
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can inform us of any changes by contacting us using the contact details provided in this policy.
Third party links
The data we collect about you
We may collect and process the following personal data about you:
- Information that you provide by filling in forms on our website.
- IP address and details of your visits to our website including, but not limited to, traffic data, location data, website logs and other communication data and the resources that you access.
- If you contact us, we may keep a record of that correspondence.
- IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Website, along with the time and duration of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating website usage levels, helping diagnose server problems, and administering the website.
- Cookies – a cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, and helps us provide a better browsing experience when you navigate our website. The cookies we use are "analytical" cookies. They allow us to recognize and count the number of visitors and to see how visitors are using our website, enabling improvements, for example, ensuring that users are finding the information they need. We use traffic log cookies to identify which pages are most popular on our website to help us analyze website page traffic. We only use this information for statistical analysis purposes, after which the data is removed from the system. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Please see our Cookies Policy for more information
- Information provided by you on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public information and may be available to visitors to the website and to the public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on the website.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose.
How we use personal data
We use your personal data to understand your needs and provide better service. In particular, we use information held about you in the following ways:
- To enable internal record keeping.
- To ensure that content from our website is presented in the most effective manner for you and for your computer, including customizing our website according to your interests and preferences.
- To provide you with information or services that you request from us, where you have given your consent.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To send you important information regarding the website and changes to our terms, conditions, policies and/or other administrative information.
- We will not sell, distribute or lease your personal data to third parties, unless we have your permission or are required by law to do so.
We may also use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. The table provided under the heading “legal basis” gives you more information. Please contact us if you need details about the specific legal ground we are relying on.
You have the right to withdraw consent at any time.
How personal data is disclosed
We may disclose your personal data, as we believe to be necessary or appropriate:
- under applicable law, including laws outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
- to enforce our terms and conditions;
- to protect our operations or those of any of our affiliates;
- to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
- to allow us to pursue available remedies or limit the damages that we may sustain.
We may also disclose your personal data to:
- Third-party service providers acting as processors who provide services such as website hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery services, payment card processing, auditing services and other similar services to enable them to provide services.
- Third-party distributors/agents that we ask to follow-up on requests from you.
Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities who require reporting of processing activities in certain circumstances.
Our third-party service providers and we may collect “other information” (which is information, that does not disclose your identity) in a variety of ways, including:
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. We use this information to help ensure that our website functions properly.
- Usage data: We may use statistical data, analytics, trends and usage information derived from your use of services (“usage data”) through pixel tags and other similar technologies. Usage data includes, for example, aggregated quantitative information about active users, activity, topics, and groups.
- Aggregated data: Aggregated data does not personally identify you or any other user of the website.
How we use and disclose other information
Please note that we may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law.
We use the services of reputable third parties to provide us with data collection and website site analytics.
We use reasonable organizational, technical and administrative measures to protect personal data under our control. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach. We will notify you and, any applicable regulator, of a breach where we are legally required to do so.
No data transmission over the Internet or data storage system is absolutely guaranteed. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.
Please note that email communications are not always secure, so please do not include financial or sensitive information in your emails to us.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, within applicable legal requirements.
We ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the website.
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Composer Atli Ingólfsson’s Website.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Italy
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Composer Atli Ingólfsson’s Website, accessible from https://www.atli-ingolfsson.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: https://www.allaboutcookies.org.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: 3rd party
Purpose: These Cookies allow our embedded content to function properly.
- Statistics Cookies
Type: Persistent Cookies
Administered by: Us, 3rd party
Purpose: These Cookies allow us to analyze Your use of and interaction with the Website, such as data related to the device/browser, IP address and on-site activities to measure and report statistics about user interactions on the website. The purpose of these Cookies is to help us understand how users interact with the Website and understand the demographics of our visitor base in order to in order to improve our services, maintain the Site and adjust our content.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
The following sets out the legal basis on which we may collect, use and retain your personal data.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):
- Identity: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud);
- Contact: Necessary to comply with a legal obligation;
To use data analytics to improve our website, services and user experience:
- Usage: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy);
To register you as a new user:
- Contact: Performance of a contract with you;
The terms referred to above having the following meanings:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
- Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Definitions and useful terms
Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
Data subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679) or UK General Date protection Regulation (UK GDPR), tailored by the Data protection Act 2018. Personal Data is subject to the legal safeguards specified in the GDPR.
Personal data under the GDPR or UK GDPR: this is any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymized Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed.
Personal data breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
Processing or process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Pseudonymization or pseudonymized: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information, which is meant to be kept separately and secure.
Sensitive personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.
Your legal rights
If you are a “data subject” under the GDPR, you have rights in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data. This is only exercisable where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.