Privacy Policy of steamcream.com

Steamcream.com collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Personal Data collected for the following purposes and using the following services:

Analytics

• Facebook Ads conversion tracking (Facebook pixel), Google Analytics, Google Ads conversion tracking, Mouseflow, Analytics collected directly and Matomo

  Personal Data: Cookies; Usage Data

• Backup saving and management

  • Backup on Google Drive

    Personal Data: various types of Data as specified in the privacy policy of the service

• Contacting the User

  • Phone contact

    Personal Data: phone number

  • Contact form

    Personal Data: email address; first name; last name; various types of Data

• Content commenting

  • Facebook Comments

    Personal Data: Cookies; Usage Data

  • Comment system managed directly

    Personal Data: first name; last name; username

• Data transfer outside the EU

  • Data transfer abroad based on consent and Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield

    Personal Data: various types of Data

• Displaying content from external platforms

  • Instagram widget

    Personal Data: Cookies; Usage Data

  • MyFonts and Google Fonts

    Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

  • Font Awesome

    Personal Data: Usage Data

• Handling payments

  • Braintree and PayPal

    Personal Data: various types of Data as specified in the privacy policy of the service

• Hosting and backend infrastructure

  • DigitalOcean

    Personal Data: various types of Data as specified in the privacy policy of the service

• Interaction with external social networks and platforms

  • Facebook Like button and social widgets and Twitter Tweet button and social widgets

    Personal Data: Cookies; Usage Data

• Interaction with live chat platforms

  • Facebook Messenger Customer Chat

    Personal Data: About Me; Cookies; Usage Data

• Location-based interactions

  • Geolocation

    Personal Data: geographic position

• Managing contacts and sending messages

  • Sendgrid

    Personal Data: email address

  • Klaviyo

    Personal Data: country; email address; first name; last name; purchase history; various types of Data

• Managing support and contact requests

  • Help Scout

    Personal Data: various types of Data as specified in the privacy policy of the service

• Registration and authentication

  • Direct registration

    Personal Data: address; billing address; city; company name; country; data relating to the point of sale; email address; house number; language; last name; password; phone number; shipping address; state; username; ZIP/Postal code

• Remarketing and behavioral targeting

  • Google Ads Remarketing and Facebook Remarketing

    Personal Data: Cookies; Usage Data

  • Facebook Custom Audience

    Personal Data: Cookies; email address

• SPAM protection

  • Akismet

    Personal Data: various types of Data as specified in the privacy policy of the service

• Tag Management

  • Google Tag Manager

    Personal Data: Usage Data

Further information about Personal Data

Analysis and predictions based on the User’s Data (“profiling”)

The Owner may use the Personal and Usage Data collected through steamcream.com to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by steamcream.com depends on the payment system used.

Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Steamcream.com may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Steamcream.com adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

• to enable or otherwise improve the decision-making process;
• to grant Users fair and unbiased treatment based on consistent and uniform criteria;
• to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
• to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within steamcream.com, Users can check the relevant sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

• obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
• challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
• request and obtain from the Owner human intervention on such processing.

To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Personal Data collected through sources other than the User

The Owner of steamcream.com may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

Unique device identification

Steamcream.com may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

User identification via a universally unique identifier (UUID)

Steamcream.com may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Contact information

• Owner and Data Controller

  STEAMCREAM Ltd
  Office 9757PO Box 6945
  London
  W1A 6US

  Owner contact email: privacy@steamcream.com

Full policy

Owner and Data Controller

STEAMCREAM Ltd
Office 9757PO Box 6945
London
W1A 6US

Owner contact email: privacy@steamcream.com

Types of Data collected

Among the types of Personal Data that steamcream.com collects, by itself or through third parties, there are: Cookies; Usage Data; various types of Data; email address; About Me; geographic position; phone number; first name; last name; username; address; password; company name; country; state; ZIP/Postal code; city; billing address; shipping address; house number; data relating to the point of sale; language; purchase history.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using steamcream.com.
Unless specified otherwise, all Data requested by steamcream.com is mandatory and failure to provide this Data may make it impossible for steamcream.com to provide its services. In cases where steamcream.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by steamcream.com or by the owners of third-party services used by steamcream.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through steamcream.com and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of steamcream.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Remarketing and behavioral targeting, SPAM protection, Handling payments, Data transfer outside the EU, Hosting and backend infrastructure, Analytics, Content commenting, Interaction with external social networks and platforms, Interaction with live chat platforms, Location-based interactions, Tag Management, Managing support and contact requests, Displaying content from external platforms, Contacting the User, Managing contacts and sending messages, Backup saving and management and Registration and authentication.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

• Backup saving and management

  This type of service allows the Owner to save and manage backups of steamcream.com on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to steamcream.com.

  Backup on Google Drive (Google Inc.)

  Google Drive is a service to save and manage backups provided by Google Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Contacting the User

  Phone contact (steamcream.com)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to steamcream.com, as well as for fulfilling support requests.

  Personal Data processed: phone number.

  Contact form (steamcream.com)

  By filling in the contact form with their Data, the User authorizes steamcream.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: email address; first name; last name; various types of Data.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of steamcream.com.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Facebook Comments (Facebook, Inc.)

  Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Comment system managed directly (steamcream.com)

  Steamcream.com has its own internal content comment system.

  Personal Data processed: first name; last name; username.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on consent (steamcream.com)

  If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
  In such cases, the Owner shall inform Users appropriately and collect their explicit consent via steamcream.com.

  Personal Data processed: various types of Data.

  Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (steamcream.com)

  If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
  In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
  Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

  Personal Data processed: various types of Data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of steamcream.com and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Instagram widget (Instagram, Inc.)

  Instagram is an image visualization service provided by Instagram, Inc. that allows steamcream.com to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  MyFonts (MyFonts Inc.)

  MyFonts is a typeface visualization service provided by MyFonts Inc. that allows steamcream.com to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Google Fonts (Google Inc.)

  Google Fonts is a typeface visualization service provided by Google Inc. that allows steamcream.com to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows steamcream.com to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

• Handling payments

  Payment processing services enable steamcream.com to process payments by credit card, bank transfer or other means. To ensure greater security, steamcream.com shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  Braintree (PayPal Inc.)

  Braintree is a payment service provided by Braintree, a division of PayPal, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable steamcream.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of steamcream.com. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  DigitalOcean (DigitalOcean Inc.)

  DigitalOcean is a hosting service provided by DigitalOcean Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United Kingdom – Privacy Policy; Germany – Privacy Policy.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of steamcream.com.
  The interaction and information obtained through steamcream.com are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on steamcream.com isn’t being connected back to the User’s profile.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of steamcream.com, for contacting and being contacted by steamcream.com support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Facebook Messenger Customer Chat (Facebook, Inc.)

  The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.

  Personal Data processed: About Me; Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Location-based interactions

  Geolocation (steamcream.com)

  Steamcream.com may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by steamcream.com.

  Personal Data processed: geographic position.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Sendgrid (Sendgrid)

  Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Klaviyo (Klaviyo Inc.)

  Klaviyo is an email address management and message sending service provided by Klaviyo Inc.

  To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

  Personal Data processed: country; email address; first name; last name; purchase history; various types of Data.

  Place of processing: United States – Privacy Policy – Opt out.

• Managing support and contact requests

  This type of service allows steamcream.com to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  Help Scout (Brightwurks Inc.)

  Help Scout is a support and contact request management service provided by Brightwurks Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow steamcream.com to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, steamcream.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Direct registration (steamcream.com)

  The User registers by filling out the registration form and providing the Personal Data directly to steamcream.com.

  Personal Data processed: address; billing address; city; company name; country; data relating to the point of sale; email address; house number; language; last name; password; phone number; shipping address; state; username; ZIP/Postal code.

• Remarketing and behavioral targeting

  This type of service allows steamcream.com and its partners to inform, optimize and serve advertising based on past use of steamcream.com by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  Google Ads Remarketing (Google LLC)

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of steamcream.com with the Google Ads advertising network and the DoubleClick Cookie.

  Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of steamcream.com with the Facebook advertising network.

  Personal Data processed: Cookies; email address.

  Place of processing: United States – Privacy Policy – Opt Out.

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of steamcream.com with the Facebook advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

• SPAM protection

  This type of service analyzes the traffic of steamcream.com, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Akismet (Automattic Inc.)

  Akismet is a SPAM protection service provided by Automattic Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on steamcream.com in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google LLC)

  Google Tag Manager is a tag management service provided by Google LLC.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

Further information about Personal Data

• Analysis and predictions based on the User’s Data (“profiling”)

  The Owner may use the Personal and Usage Data collected through steamcream.com to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
  The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by steamcream.com depends on the payment system used.

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Steamcream.com may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Steamcream.com adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within steamcream.com, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

• Personal Data collected through sources other than the User

  The Owner of steamcream.com may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

• Unique device identification

  Steamcream.com may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

• User identification via a universally unique identifier (UUID)

  Steamcream.com may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Steamcream.com uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of steamcream.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, steamcream.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, steamcream.com and any third-party services may collect files that record interaction with steamcream.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Steamcream.com does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within steamcream.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.