Privacy Policy

With Papers, LLC (“With_Papers”) is committed to protecting your privacy online.

We have prepared this Privacy Policy to explain to you how we collect, use and share your personal data. This Privacy Policy governs all mobile applications and websites owned or operated by With_Papers, including the website located at www.with-papers.com and any other websites, applications, interactive features, widgets and resources offered by With_Papers through Internet websites, mobile devices or other platforms (all of which are collectively referred to as the “Service”). We will treat all of the information you provide through our Service, including your registration information, with the utmost respect. We work diligently to ensure that we have taken all appropriate administrative and technical measures to prevent the unauthorised or unlawful use of your personally identifiable information, and to prevent any accidental loss or destruction of, or damage to, such information.

By accessing or using our Service, you agree to be bound by by this Privacy Policy. If you do not agree to these terms, please do not access or use this Service.

Collection of Information

The Service provides tools for you to correct, update, or edit your personal data and control your profile. You can edit your profile and other information at any time through the Service.

When you register to become a member of the Service, we collect certain information about you which may include such information as your name, e-mail address, home address, phone number and date of birth, as well as other information deemed appropriate. When you provide us with personal data to complete a transaction, verify your credit card, other payment-related information, place an order, you consent to our collecting it and using it for that specific reason only.

We may also collect other personal data, including, without limitation, any personal data that you provide to us through the Services or in connection with any contests and/or other promotions (collectively, “personal data”).  When you post comments or content through the Service, your username and other personal data may be included in the message. 

If we ask for your personal data for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

Information We Collect Automatically

We automatically collect certain non-personal data to help us understand how our users use the Service (which we will refer to in this Privacy Policy, collectively, as “usage data”).  

We may automatically collect and use the data contained in log files.  The information in log files may include your IP address, your ISP, the Web browser you used to visit the Service, the time you visited the Service, which web pages you visited on the Service, and other anonymous usage data. 

With_Papers uses the information that we collect about you to improve your browsing experience by personalising our Services to your interest, and also to help us to select content and services that you may find interesting and useful. Information about the content you visit and services you use may be used alone or in conjunction with information collected from other users to help us tailor our website and our other products and services to better suit the needs and interests of you and other users.

Information that you provide may also be used as part of our effort to keep you informed about events and selected products and services that may be of interest to you. In some cases, we may contact you with information from carefully selected third parties, but these service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

Use and Disclosure of Personal Data

We will primarily use your personal data collected from you for business operational purposes related to Services in order to notify you of new services, send service notifications, process citizenship and/or immigration request and inquiries, customize the advertising and content you see, improve our services, conduct market research, resolve disputes, collect fees, troubleshoot problems and solicit your feedback and input about the Service. Occasionally we offer current subscribers the chance to participate in contests or promotions.

Sharing Your Information.

Other than as set forth in this Privacy Policy, except for aggregate information that we may share with third parties in a manner that does not link such information to any individual, we will not share your personal data with third parties for marketing purposes and only share your information as described herein. Please note that certain personal data becomes public record when documents are filed with Italian governmental or administrative authorities or a court. This Privacy Policy does not cover such information or any similar filings or actions.

We may sometimes use other businesses (“Service Providers”) – to perform certain services for us, i.e. payment processing, hosting and maintenance, data storage and management services, production and fulfilment, and marketing and promotions – such as Google Tag Manager, Google Analytics, SiteGround Hosting, Mailchimp, Widget Video YouTube, YouTube Data API. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure.

Without limiting the above, we may occasionally be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities to (i) comply with laws, regulations, court orders or subpoenas or in response to a government request; or (ii) protect or exercise our legal rights or defend against legal claims.

We may share information about users with business partners, sponsors and other third parties.. However, please be assured that this aggregate data will not involve the disclosure of personal data nor personally identify you or any other users of the Service.

Other Authorized Disclosures

Notwithstanding anything in this Privacy Policy to the contrary, you understand and agree that With_Papers may access, preserve and disclose any information we have collected about you or that you have submitted: (i) in response to subpoenas, court orders or legal process, or to establish, protect or exercise our legal rights or defend against legal claims; (ii) to protect the rights and property of With_Papers, its affiliates, or the public; (iii) if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, copyright violations, trademark violations or other violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person; and (iv) if With_Papers is acquired by or merged with another entity or in connection with a sale of our assets.  

Public Areas

Your use of areas of the Service that are intended for interaction with other users may reveal your username and may allow you to publish certain personal data about you.  By choosing to use these areas, you understand and agree that anyone with access to those areas may access and forward any information about you that is contained in or that you post to those areas.  As with any social networking service, you should use care when disclosing your personal data to strangers. 

Links to Other Sites

The Service may contain links to websites operated and maintained by third parties over which we have no control.  Privacy policies on such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk.  We encourage you to review the privacy policy of any such linked website you visit to understand that website’s collection, storage, and use of your information.  

Security

The security of your personal data is important to us.  We use standard security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification or disclosure.

The personal data that we collect from you may be stored on a mix of various cloud provider platforms and may be transferred to, and stored outside the European Economic Area (“EEA”).  It may also be processed by staff operating outside of the EEA who works for us, one of our businesses offices or third party authorities. Where we do so, the third country’s data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place.   

Where such transfers occur, we ensure the confidentiality and protection of all data is preserved through compliance with legal requirements and the current Data Protection legislation. Data encryption, integrity and confidentiality are enforced by following best practice  No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.  As a result, while we strive to protect personal data, we cannot and do not guarantee or warrant the security of any information you transmit to or from the Service, and you do so at your own risk. 

If you are an EU national and are have questions regarding the transfer and sharing of data outside the EU, please contact us if you require further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EU.

Your Rights as Users and Retention of Personal Data

You have several rights under the data privacy legislation. Specifically, users have the right to do the following:

  • Right to obtain a copy of your personal data. You have the right to obtain a copy of the personal data we hold about you. 
  • Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal data. We will then correct our records, and notify any third parties to whom such personal data may have been transmitted as described above. 
  • Right to data portability. You may request a copy of all personal data you have provided to us after which we will transmit said data to another data controller of your choice. 
  • Right to opt-out of marketing communications. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. 
  • Right to withdraw consent. You may withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal data is essential. 
  • Right to object to processing. You may request that we stop processing your personal data. Please note you may not be able to benefit from certain service features for which the processing of your personal data is essential. 
  • Right to erasure. You may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. 
  • Access their personal data. Users have the right to learn if personal data is being processed by With_Papers, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
  • Restrict the processing of their personal data. Users have the right, under certain circumstances, to restrict the processing of their personal data. In this case, With_Papers will not process their personal 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 personal data from WIth_Papers.
  • Receive their personal data and have it transferred to another controller. Users have the right to receive their personal 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 personal 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.

If you wish to exercise any of these rights, please email us at contact@with-papers.com with subject heading: Privacy.

Children’s Privacy Statement

We do not knowingly collect personally identifiable information from children under the age of thirteen (13).  If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen (13), we will delete such information from our records.  Because we do not knowingly collect any personally identifiable information from children under the age of thirteen (13), we also do not knowingly distribute such information to third parties. 

Period of Data Storage

We will not keep your personal information for any purpose(s) for longer than is necessary and we will only retain the relevant personal information that is necessary in relation to the purpose. We are also required to retain certain information by law or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

We will retain your data until you opt-out of receiving electronic direct marketing or for two years from the date of your last consent to receive electronic marketing.

We may retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any disposal to take place.

Changes

With_Papers may, in its sole and absolute discretion, change this Privacy Policy from time to time. Your continued use of the site after such modifications will constitute your (i) acknowledgment of the modified Policy; (ii) agreement to abide and be bound by the modified Policy.

With_Papers is committed to safeguarding your privacy while providing citizenship and/or residency service to you. We encourage you to periodically review this statement as it may change from time to time at our sole discretion. This Privacy Policy statement explains the personal data gathering and use practices of With_Papers. If you would like to ask questions or provide comments regarding this Privacy Policy you may do so by sending us an e-mail to contact@with-papers.com indicating the subject matter: Privacy.

Updating Your Personal Data

You may change and control any of your personal data in your account online at any time by logging on to your account and editing your information.

Lawful Basis for Processing Personal Data

Our lawful basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. 

However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect vital interests.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the lawful basis on which we collect and use your personal data, please contact us by sending us an e-mail to contact@with-papers.com indicating the subject matter: Privacy.

Dispute Resolution

If a situation arises, where you have a privacy dispute, please contact With_Papers directly and we will be glad to work in a fair and practical way with you. Our contact info is indicated under Contact Us or send an email to contact@with-papers.com indicating the subject matter: Privacy. If your communication with With_Papers has not led to a mutually agreeable resolution, we shall participate in the dispute resolution procedures established by the American data protection authorities to resolve disputes.

Cookie Policy

In addition, we may use a technology called “cookies” and similar technologies.  A cookie is a small file that identifies you as a unique user. We may use cookies to improve the quality of our Service and make the Service easier to use.  We do this by storing information (for example, settings preferences) about a particular user session in cookies in order to provide you with a seamless experience during a particular session.  Certain of our service providers may use cookies or similar technologies in connection with the services they perform on our behalf. If you choose to do so, you can configure your browser to delete existing cookies or disable cookies altogether.  However, certain features of the Service may not work if you delete or disable cookies.