In order for us to operate our business and provide our services to you, it is sometimes necessary for us to collect or process information about you. In general terms, this information will take one or more of the following forms:
Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
Information that is automatically sent to us by your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.
Our commitment to data privacy
We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.
Our systems and services are designed with privacy in mind, and we operate a ‘data minimization’ principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary. We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’) and ePrivacy Directive, where applicable.
Who we are
In terms of your use of this website, we, Genovesi Web Design and Marketing, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:
Data Controller: Genovesi Web Design and Marketing
Address: 17 Moehring Dr, Blauvelt, NY 10913
Who we share data with
We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. The only people/organizations that are granted access to personal data are:
Employees of Genovesi Web Design and Marketing who provide design and/or support services; Our web hosting technology suppliers (currently Webflow and Amazon) who provide the physical server infrastructures that our website(s) operate on. We ensure that all servers in use reside physically in the United States, and that no customer data is transferred to data centers outside the United States. We have signed Data Privacy Agreements with all of the 3rd party technology suppliers above which detail our respective responsibilities for data security.
Definition of ‘personal data’
When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data. Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, because in their current form, European data privacy regulations are somewhat vague in this regard, we will cover the use of such data here also.
How your data is protected
We take the security of all personal data very seriously, and that data is protected in a number of ways:
Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced
Dedicated security software: We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
Data encryption: where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.
This website is also secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.
Selection of third party service providers: we use a very limited number of third party service providers, but some are essential for the provision of physical hosting environments and cloud services. One of the core factors in the selection of such providers is their ability to provide secure systems and processes. We have written Data Processing Agreements with each of our core service providers that sets out the requirements for data security.
Access to your personal data
In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:
You have the right to obtain from us confirmation about whether any such data is being held;
You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
Even if you have consented to us processing your personal data, you have the right to withdraw that permission at any time;
You have the right to require us to rectify any incomplete or incorrect information held about you;
You have the right to require us to erase the data held about you (the ‘right to be forgotten’);
In the situation where we collect personal data automatically (such as from your internet browser or via internet
Cookies or other similar technologies):
You have the right to object to the legal basis upon which we are collecting this data, and we have an obligation to consider and respond to that objection;
You have the right to request the prevention of further processing of your data while your objection is considered;
You have the right to make a complaint to the relevant data protection authorityIn most circumstances, you can exercise these rights without paying a fee to us.
Types of data collected:
Website contact forms
When you complete one of the contact forms on our website, we will ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.
If you do not use or submit an online form on the website, no data will be collected in that regard.
Intent to contract (GDPR Art 6(1)(b)): Additionally, the information that you provide to us here is necessary for us to fulfill your request prior to entering into a contract.
Types of processing
We will store the information you provide to us in our website database, and/or in our self-managed Customer Relationship Management system. Such storage allows us to efficiently access your data and respond to your requests;
For the purpose of maintaining the integrity of our systems, we may also store this data in system backups, which are encrypted and held securely by our technology partner Amazon Web Services;
We may use this information to contact you about other of our own services that we believe may be of genuine interest to you;
We will NOT use this data for any further purpose without your express further consent;
We will NEVER sell your information to any 3rd party.
We will only ask you for the minimum amount of information required to appropriately fulfill your request. This will usually be your name, one or more contact details, and any specific information about your request.
Technical data (such as ‘IP address’)
When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.
Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behavior (such as repeated malicious attempts to access a system).
IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.
Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.
In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:
Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.
Types of processing
We will store the information you provide to us in our website server logs
For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
We will NOT use this data to attempt to identify an individual person
We use Google Analytics to better understand what people look at on our website.
When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Google Analytics (which is controlled by Google).
The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.
We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.
As analytics information is not personal data, we do not specifically ask for your prior consent.
Other Google Services
In addition to Google Analytics, we use a number of industry-standard Google services to provide particular pieces of website content. These include:
Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
Google Maps: We may use Google’s mapping services to provide dynamic geographic maps on our website
Each of these services involve our website making a connection to one or more Google servers, and may result in Google placing cookies on your device.
Google Fonts & Maps
By using Google Fonts, we make a connection to the Google Fonts API and, unless your browser has already stored a copy of the font in use (by virtue of visiting another website that uses it), your browser will download a copy of that font. This all happens in near real time, and means that our website content will be displayed on your device in the way we had intended it, regardless of whether the particular font is installed on your device.
The Google Fonts API connection is unauthenticated, meaning that it will work regardless of whether you are logged into Google. It does not rely on cookies being sent to Google. Google may capture your device’s IP address as part of this process, and uses this data only in aggregate form to understand the popularity of individual fonts. More detail can be found on the Google Fonts FAQ page.
We only use Google Maps functionality to show dynamic maps on our website, and not in any way to detect or track your location.
We consider that it is in our Legitimate Interest to process data in this way under GDPR Article 6(1)(f). The use of Google Fonts and Maps is a means of ensuring a clear and consistent display of our web content, in a way that improves user experience. The data collected by Google is extremely limited and we consider that it has negligible impact on individuals’ data privacy.
Like the vast majority of commercial websites, we use social media cookies from Facebook on our site. The cookies are placed by Facebook, and we use them to understand the effectiveness of social media campaigns that we operate.
If you are not logged into Facebook when you view our site, then it is not possible for any personal information about your visit to be collected, and therefore we do not specifically ask for your prior consent.
If you are logged into Facebook when you view our site, then Facebook will know when you visit us. We do not have any access to the detail of that personal data, as you have consented to share it with Facebook, not us. We just get to see anonymized data about the numbers of people who have responded to our advertising or other social media activity.
There are a number of ways of controlling the ads that you see based upon your activity on Facebook. The following resources may help to understand those choices:
How to opt-out of Facebook interest-based advertising on your browser or mobile device: https://www.facebook.com/help/568137493302217
About Ads: http://www.aboutads.info/choices
Your Online Choices: http://www.youronlinechoices.eu/
You can always use your browser’s ‘private’ or ‘incognito’ mode to browse websites anonymously.