Improve your Empowerment
Privacy Policy
In short. This site does two things: it shows you what EMPOKERMENT® is, and it lets you leave your email address so we can tell you when the trial version opens. Google Analytics 4 works only with your consent: until you say yes to analytics, no request leaves this site for Google, on any page. On the pages that do not show the banner, the choice you saved on the home page applies. We measure instead with a tool of our own, which runs on our server and passes through no third party: it counts how far down the page you get, how long the page stays open and what is clicked, and keeps totals only. It installs no cookie, writes nothing on your device and creates no identifier: that is why it works without consent, and it serves one purpose only — to understand which content is read, so that we can write it better. If you do not want it, write to us and we will exclude you. If you accept analytics cookies, the measurement is complete and we count how many people visit; if you also accept marketing cookies, the Meta pixel helps us measure our advertising campaigns and show our ads to people who have visited the site. Nothing else. We sell your data to no one, and you can have yourself removed at any time with a single message.
1. Data controller
All In Channel Entertainment & Communication di Pietro Semeraro
Via Carnaga, 29 — 21100 Varese (VA), Italy
VAT number 03440510125 — ROC no. 25933
Email: infoprivacy.dpo@allinchannel.com
Certified email (PEC): allinchannel@pec.it
No Data Protection Officer has been appointed: the processing carried out at this stage does not fall within the cases in which appointment is mandatory.
2. What data we process, why, on what basis and for how long
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Email address | To send you updates on the project and to tell you when the trial version opens | Consent — Art. 6(1)(a) GDPR | Until you withdraw consent and in any case no longer than 24 months from the last meaningful contact |
| Proof of consent: date and time, IP address, wording accepted and version of this policy | To demonstrate that consent was validly given | Legal obligation — Art. 6(1)(c) and Art. 7(1) GDPR | For as long as you remain subscribed and for the following five years, for evidential purposes. If you ask for erasure, it is deleted together with everything else: the evidence does not outlive your request |
| Browsing data recorded by the server: IP address, date and time of the request, page requested, browser | To keep the site running, security, defence against abuse and attacks; aggregate visit statistics in our internal dashboard, including the approximate area of origin (country and city), determined on our own server from the IP address, which is not stored, to measure the quality of the Controller's content, with no transmission to third parties | Legitimate interest — Art. 6(1)(f) GDPR | 6 months; aggregate and anonymous totals without a time limit |
| The Controller's own measurement tool: page opened, maximum percentage of the page reached, time the page stayed open, clicks on links and buttons, screen width, site you arrived from | To measure the quality of the site's content: which pages are read, how far, and what is clicked | The Controller's legitimate interest in measuring the quality of its own content — Art. 6(1)(f) GDPR. The tool installs no cookie and creates no identifier on your device, so it does not require the consent of Art. 122 of the Italian Privacy Code | Aggregate totals by day and by page only, with no IP addresses and nothing that concerns you: no transfer to third parties. You may object at any time by writing to infoprivacy.dpo@allinchannel.com |
| IP address of the request, used to determine the country you are browsing from | To apply the territorial restrictions of the service: from the countries where the service cannot be accessed the site shows a page explaining this, and the sign-up form cannot be used | Legitimate interest in complying with the rules that apply in each country — Art. 6(1)(f) GDPR | The country is determined on our own server at the moment of the request, using a local database, and is not stored. For this purpose no data is sent to third parties. Only for programs that present themselves as search engine or social network crawlers, the result of checking their address is kept for up to six hours, as an unreadable fingerprint |
| Form protection: an invisible field that only automated programs fill in, and a count of submission attempts per network address | To prevent automated sign-ups and abuse of the form | Legitimate interest in the security of the service — Art. 6(1)(f) GDPR | Attempts are deleted automatically after 24 hours. The check runs entirely on our own server: no data is passed to any third party |
| Results of email communications: delivery, opening of the message (detected with a one-pixel image, an indicative figure), links clicked in the message, date and method of unsubscribing | To know whether the messages arrive and are of interest, to decide what to write and to whom, and to stop writing to those who do not open them or who have unsubscribed | Consent to communications — Art. 6(1)(a) GDPR; one-click unsubscribing is in the message itself and in its technical button | For as long as you remain subscribed; the date and method of unsubscribing for the following five years, for evidential purposes |
| Register of cookie choices: date and time of the choice, what was chosen and with which button, the version of the privacy and cookie policies then in force, language and page, a random code for the choice and a non-reversible fingerprint of the network address | To be able to demonstrate that consent to cookies was given, changed or withdrawn, as the law requires of the Controller | The controller's obligation to demonstrate consent — Art. 7(1) GDPR, in relation to Art. 6(1)(a). The register does not keep your IP address, only a salted fingerprint from which the address cannot be recovered | 5 years from the choice, for evidence, then automatic deletion |
| Cookies and measurement identifiers (Google Analytics 4) | To count visits, understand which channels they come from and how many people leave their email | Consent collected through the banner — Art. 122 of the Italian Privacy Code and Art. 6(1)(a) GDPR. Without consent Google Analytics 4 is not loaded and receives nothing | As stated in the cookie policy; consent is requested again after six months |
| Marketing cookies and identifiers (Meta pixel): pages visited, completed sign-up, browser and device identifiers, IP address | To measure the results of our advertising campaigns on Meta platforms (Facebook, Instagram) and to show our ads to people who have visited the site (targeted advertising) | Consent to the marketing category, collected through the banner — Art. 122 of the Italian Privacy Code and Art. 6(1)(a) GDPR | As stated in the cookie policy (_fbp and _fbc: 90 days); consent is requested again after six months; Meta keeps the data according to its own policy |
The country is determined using the IP to Country Lite database by DB-IP, licensed under Creative Commons Attribution 4.0. The city is determined using the IP to City Lite database by DB-IP, under the same licence.
Signing up is completed by a confirmation: after you submit the form you receive a message with a link to open. Until you open it, your address stays pending and receives nothing else. This verifies that the address really belongs to the person who entered it. When the trial version opens, anyone who has already confirmed will not have to verify their address again: they will only need to choose their player name.
At this stage we do not collect first name, surname, player name, date of birth, telephone number, payment data or game data: neither accounts nor games exist yet.
How we measure communications. Every message we send you contains a one-pixel image and links that pass through an intermediate address of ours carrying your internal code: this is how we know whether the message was opened and which link was clicked, and we note it on your record. Opening is an indicative figure, because many email programs block images or load them automatically. On the site we recognise you only when you arrive from a link contained in a message: anyone arriving from a search or by typing the address remains an anonymous visitor. You can stop all of this at any time with the unsubscribe link, found at the bottom of every message and in the unsubscribe button of your email program: one click, no login and no confirmation.
3. Providing your data is optional
You can read every page without giving us any data. Leaving your email address is your free choice: without it you will not receive the announcements, but nothing else is denied to you. Consent to communications is separate, optional and is not a condition for any other service.
4. Recipients and data processors
Your data is never sold, nor transferred to third parties for their own marketing, except as stated below for the Meta pixel, which is active only with your consent. It is processed, besides by the controller, by the following providers, appointed as processors under Art. 28 GDPR:
| Provider | Role | Where it processes the data |
|---|---|---|
| MailUp S.p.A. (Growens group), Italy | Platform for sending communications and managing the list | Italy — European Union |
| A2 Hosting, LLC — Hosting.com (Delaware, United States). Representative in the Union under Art. 27 GDPR: Hosting Holding Germany BidCo GmbH, Kennedy-Ufer 11, 50679 Cologne, Germany | Website hosting and retention of server logs | European Union and United States, depending on the data centre assigned to the account |
| Google Ireland Ltd. | Visit measurement (Google Analytics 4), only with consent: without consent the tool is not loaded and nothing reaches Google | European Union, with possible transfers to the United States |
Meta Platforms Ireland Ltd. receives the data of the Meta pixel only if you accept the marketing category. It is not a processor: it is joint controller with us for collecting and transmitting the data through the pixel, under the joint controller addendum Meta makes available to businesses, and an independent controller for the subsequent processing it carries out for its own purposes, described in Meta's privacy policy.
Data may also be disclosed to professional advisers and public authorities where necessary to comply with legal obligations or to defend a legal claim.
5. Transfers outside the European Economic Area
The contact list is managed in Italy. Transfers to the United States may instead occur through the hosting service, when the assigned data centre is located outside the Union, and through the measurement and marketing services (Google and Meta, whose parent companies Google LLC and Meta Platforms, Inc. adhere to the EU-US Data Privacy Framework). In those cases the transfer relies on the European Commission's adequacy decision on the EU-US Data Privacy Framework and, in the alternative, on the Standard Contractual Clauses, together with the supplementary measures declared by the providers and the processing agreements signed with each of them.
6. How we protect your data
The sign-up form is protected by checks entirely our own, running on our own server: an invisible field that only automated programs fill in, a limit on repeated attempts, and confirmation of the address with one click in the email. No third-party anti-spam service is active: filling in the form contacts nobody but us. If we ever activate one, it will be stated here before it is used.
The site is served over an encrypted connection. Access to the contact list is limited to the people who actually need it, with individual credentials and, where available, two-factor authentication. We collect the minimum necessary for the stated purpose.
7. Your rights
You may exercise the rights set out in Articles 15 to 22 GDPR at any time:
- access: to know whether we process data concerning you and to obtain a copy of it;
- rectification: to correct inaccurate or incomplete data;
- erasure: to be removed from the list and from our records;
- restriction of and objection to processing;
- portability: to receive your data in a machine-readable format;
- withdrawal of consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
To exercise them write to infoprivacy.dpo@allinchannel.com: we reply within one month, extendable by two further months in complex cases, of which we will inform you. Every message we send also carries a one-click unsubscribe link.
You have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (Piazza Venezia 11, 00187 Rome — garanteprivacy.it), or with the supervisory authority of the country where you live, or to bring proceedings before a court.
8. Automated decision-making and profiling
Only if you accept the marketing category, the Meta pixel allows Meta to include your visits to the site in audiences to which our ads are shown: this is profiling for advertising purposes, which you can refuse or withdraw at any time without consequences for the use of the site. Apart from this we carry out no profiling, and we take no automated decisions producing legal effects concerning you or similarly significantly affecting you.
9. Minors
The site and the project are addressed to adults. By leaving your address you declare that you are at least 18 years old. If we become aware that an address belongs to a minor, we delete it without delay. When the trial version opens, registration will require a date of birth and the specific rules will be stated in the Terms of Use then in force.
10. Cookies
The use of cookies and similar tools is described in the cookie policy, which states which tools we use, what they are for and how to withdraw consent.
11. Changes
This policy will be updated as the platform evolves: registration with a player name, game history and activity data will each require new sections. Every version is published here with its number and date of entry into force; we will notify subscribers by email of material changes before they take effect.