1. Data Controller

Brian Davidson on behalf of Frost & Found with registered office in 285 Saint George Street Duxbury US (the “Company” or the “Controller”) is ensuring compliance with the rules on personal data processing by providing the following information on the processing of data that is received, or in any case collected, while browsing this site.

2. Processed data, purpose and legal grounds for processing

Data generated by accessing the site

The information systems and the software used for this service acquire, during their normal use, certain personal data which is implicitly transferred while using Internet communication protocols. Such data (such as, for example, domain names, IP addresses, operating system used, type of device and browser used in the connection) is not coupled with any additional personal information and is used for: i) retrieving anonymous statistical information on the use of the site; (ii) managing control needs of the methods used for site browsing; and iii) ascertaining liability in the case of cybercrime. The legal ground for processing data is to render the site’s features functional following the user’s access.

Data voluntarily provided by the user

The personal data provided by the user through the form is collected and processed for the following:

• Carrying out our on going engagement activities with our users/customers (via emails, SMS, push notifications, ...);
• administrative purposes and performing obligations under the law, for example, accounting, tax, or adhering to court orders;
• Having received specific consent, sending newsletters and marketing materials, periodically;
• Having received specific consent, receiving updates on our activities and new postings on our blog;
• Having received specific consent, receiving promotional notices on event invites, training, webinars, special promotions or participating in market research and analysis;

The legal ground for processing data is the execution of a contract to which the data subject is a party or the execution of precontractual measures adopted upon requests of the same. In the cases expressly stated, the legal grounds for processing data is the consent freely given by the data subject.

Data collected through the platform

For further detailed information, we hereby specify that in the notices sent, our system, through statistical data collection (for example, web beacons), allows us to check whether a message was viewed, count the number of clicks on hyperlinks contained within the message, record the IP address or the type of browser used to open the email, and check similar details. The collection of such data is necessary for the use of the platform and constitutes a substantial part of the site’s functionality to send messages. The legal grounds for processing data is the execution of a contract to which the data subject is a party.

3. Nature of data provision

Aside from what is specified for browsing data and for data collected through our system, the provision of data is: Optional, with regard to the purposes under a), b) and f) but any refusal shall make it impossible for the system to perform its undertakings pursuant to the contract obligations; Optional, with regard to the purposes under c), d) and e) and their use is conditional on having obtained a specific consent. Any refusal shall make it impossible for us to deliver the service.

4. Processing methods and length of storage

The data collected shall be processed using electronic, or in any case, automated, computer and telematic, or manual methods that are logically strictly related to the purpose for which the personal data was collected, and in any case, in a manner to guarantee the security of the same. The data shall be stored for a term that is strictly necessary for the management of the purposes for which the data was collected, in compliance with the law in force and the legal obligations. In any case, the system has enacted practices that prohibit the storage of data for an indeterminate term and therefore limits the storage term in compliance with the principle of minimizing data processing.

5. Persons authorised to process data, data processors and disclosing of data

Data processing of the data collected is carried out by persons working within Brian Davidson that are appointed for this end and authorised to process data according to specific rules provided under the law in force.

The data collected, if necessary or fundamental to execute the indicated purposes, may be used by external third-party processors that can complete the service you are using (market analysis and research, management of payments through credit cards, information system management, ...).

The data collected may also be transferred abroad, to companies both belonging and not belonging to us, in the form and manner envisaged in the current law, guaranteeing, in any case, an adequate level of protection.

In any case, personal data shall never be disseminated.

6. Data Subject’s Rights

It is possible to access, object to the processing or request the erasure, the modification or the updating of all the personal data collected by us, at any time, by exercising the right to limit the data processing and the movement of data, by sending an email to: brian@distilledagency.com.

7. Data Processor

The controller has appointed the data processor, who may be contacted via the following email: brian@distilledagency.com.