UNDER ARTICLES 13 – 14 OF EU REG. 679/2016 and ARTICLES 13 – 14 OF SAN MARINO LAW 171/2018

1. Data Controller
The Data Controller in charge of the data collected through this website is Funnel Company Srl, with registered offices in Strada Degli Angariari 3, Falciano (Republic of San Marino), Economic Operator Code SM27916 (hereinafter also referred to as the “Controller”).

2. Purposes and legal grounds for processing



Collection of data and information solely in aggregated and anonymous form in order to verify proper operation of the website. Such information is not associated with the physical user of the website, and in no way permits identification.

Legitimate interest of the Controller (statistics and operation of the website), no consent required.

Possible collection of data and information to protect the security of the website (antispam filters, firewall, virus detection) and of users and to prevent or expose fraudulent use or abuse of the website. Data is recorded automatically and may also include personal details (IP address) that could be used, in accordance with applicable laws, to block attempts to damage the website or to harm other users, or any other form of harmful or criminal activity. Such data is never used to identify or profile the user and is deleted regularly.

Legitimate interest of the Controller (website security), no consent required.

Collection of data for the purpose of analysing and processing information concerning users and their preferences, habits, consumption choices and/or browsing experiences. To this end, data may also be collected through the use of technologies such as (proprietary or third party) cookies. Collection of data through the use of cookies takes place with the user’s consent expressed through the applicable banner, or with use or consultation of the website, which will be regarded as conduct implying intent.

Consent of the data subject

Collection of data (e.g. first name, last surname, e-mail, etc.) in the opt-in forms used by data subjects to register for conferences and events or to request free training material. 

Implementation of contractual and pre-contractual measures for purposes related to the user’s request

Collection of general data (first name, last name, e-mail, telephone number) so as to e-mail messages, telephone contacts, newsletters, informative material, and commercial communications on the services offered by the Controller (similar to those already purchased), and to detect the degree of satisfaction with the quality of services (soft spam or direct marketing). Collected data is stored and managed via ClickFunnels so as to create marketing campaigns and newsletters. While profiling activities are in fact conducted, these do not fall within the cases foreseen by article 22 of EU Reg. No. 679/2016, meaning that the prior acquisition of consent is not required.

Legitimate interest of the Controller

In order to conduct market analyses and monitor sales performance, the Controller will upload the contractual data collected via this website to the database of its Conversion Control ERP system.

Legitimate interest of the Controller

3. Consent and consequences of refusal
Consent is given through an applicable banner or, if said banner is ignored, through use or consultation of the website, which will be unequivocally regarded as conduct implying intent. By using or consulting the website, visitors and users approve this privacy policy and consent to the processing of their personal data in the manners and for the purposes described below, including any communication to third parties considered necessary for the provision of a service. The provision of data and consent to the collection and processing of the data are optional. Users may deny consent or, at any time, withdraw any previously provided consent (through the banner at the bottom of the page or the browser’s cookie settings). However, denying consent may make it impossible to provide certain services and may affect the user’s browsing experience. 

4. Data processing methods
Your data is processed through the use of suitable tools and procedures such as to guarantee their security and confidentiality. Processing may occur both via our website and by means of other electronic instruments, and sometimes also in paper form. In addition to the Controller, in some cases the data may be also accessed by other parties involved in the organisation of this website (administrative/commercial staff, system administrators, etc.) or by external parties (third-party technical service providers, hosting providers, computer companies, communication agencies, etc.), who, in the cases provided for by law, will be appointed Data Processors by the Controller. The updated list of Data Processors may be requested at any time from the Data Controller.

5. Data retention period
Data collected by the website during its operation is stored for the time strictly necessary to carry out the specified activities. On expiry, the data will either be deleted or made anonymous, unless specific reasons exist for retaining same. The Controller has no control over cookies fully managed by third parties and has no access to the information collected through these cookies. For more details on the retention of data collected through cookies, please refer to the cookie policy.

6. Transferring data to foreign or non-EU countries
Please note that, in accordance with article 46 of San Marino Law 171/2018, the Controller may transfer your personal data within the European Union. Moreover, in compliance with the provisions of articles 45 and 46 of said Law 171/2018, the Controller may transfer your personal data outside the Republic of San Marino, also to non-EU countries. In such cases, the Data Controller hereby guarantees that transferring data to a non-EU country will take place in compliance with applicable provisions of law. Moreover, if need be, the Data Controller will stipulate agreements guaranteeing an adequate level of safeguards and/or inserting the standard contract clauses provided by the European Commission and/or binding company rules.

7. Accessing and communicating data
Your data may be made accessible to the Controller’s employees and collaborators in their capacity as Data Processing Operators and/or system administrators, and also to third-party companies or other entities (e.g. professional firms, consultants, software houses providing ERPs – e.g. ClickFunnels -, credit institutions, insurance companies, etc.) to whom activities are outsourced by the Controller, in their capacity as external data processors. The Controller may communicate your data to Public Administrations, supervisory bodies and/or judicial authorities, as well as to any other entity to whom communication is mandatory or made necessary by law. Your data will not be disseminated.

8. Processing methods
Your personal data will be processed by means of the operations set forth in article 4(2) of EU Reg. 679/2016 and article 2(b) of San Marino Law 171/2018, namely: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, alignment or combination, restriction, erasure or destruction. Your personal data may be subject to both paper and electronic processing. Processing is carried out by data processing operators and employees, as part of their respective duties and in compliance with the instructions received, exclusively for the fulfilment of the applicable purposes and scrupulously observing the principles of confidentiality and security required by the applicable legislation.

9. Rights of the data subject
Pursuant to articles 15 to 22 of San Marino Law 171/2018 and articles 15 to 22 of EU Reg. No. 679/2016, the data subject may exercise specific rights. In particular, the data subject has the right: a) to obtain confirmation as to whether or not personal data concerning him or her is being processed, and, where that is the case, access to the personal data; b) to request rectification of incorrect personal data and or completion of incomplete personal data; c) to request erasure of the personal data concerning him or here, where allowed by the regulation; d) to request restriction of processing, in the cases provided for by the regulation; e) to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort; f) to receive, in a structured format, commonly use and machine-readable format, the personal data provided to the Controller, and to transmit said data to another controller, at any time, even upon termination of the relationship with the Data Controller; g) to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. Where personal data is processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.; h) not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her; i) to lodge a complaint with a supervisory authority pursuant to article 77 of EU Reg. No. 679/2016 and article 66 of San Marino Law 171/2018.

 Any such requests should be e-mailed to the data controller at

10. Representative in the European Union
In accordance with articles 3 and 27 of EU Reg. No. 679/2016, please note that the Data Controller has appointed as its representative in the European Union the company CONSULENTI PRIVACY SRL, with registered offices in Via Valentini 11, Tax ID and VAT No. 04391970409, ph. +39 0541 1798723, e-mail, certified e-mail


11. Updates
This privacy policy was updated on 22/12/2020.