INTRODUCTION

This Privacy Policy is intended to describe the way in which the company M&M First LLC manages and processes the personal data of users who visit this website.

This is a statement that has been prepared pursuant to applicable US laws, including:
– The California Consumer Privacy Act (CCPA)
– The California Privacy Rights Act (CPRA)
– The Virginia Consumer Data Protection Act (VCDPA)
– The Colorado Privacy Act (CPA)
– The Connecticut Data Privacy Act (CTDPA)
– The Utah Consumer Privacy Act (UCPA)

The Policy Information is written to inform users who interact with the web services provided by the company M&M First LLC and the website mmfirst.online.

DEFINITIONS

Personal data

Personal data are informations that allows to identify directly or indirectly a natural person (such as: name, surname, email, telephone number).

User

For the purposes of this privacy policy, the “user” is defined as the natural person who navigates and uses this Site.

While browsing on this site, the user will be given a notice in which he will be asked to authorize the tracking of his “cookies”.

By authorizing the tracking of “cookies” the user usage data will be anonymized (“anonymized cookies”) by not allowing this website to directly identify the same user.

Interested

If the user visiting this site authorizes the processing of his personal data (by filling in a contact form) the same will be defined as “interested”, or the subject to whom the personal data refer.

Usage Data

These are the information that this site automatically collects without directly identifying users.

In particular, they are usage data for this site:
– the IP addresses or the domain names of the computers used by the user who connects with this Site;
– the addresses in URI (Uniform Resource Identifier) notation;
– the time of the user’s request;
– the method used in submitting the request to the server;
– the user’s country of origin;
– the characteristics of the browser and operating system used by the user;
– the duration of the user’s visit to the pages of this site;
– the user’s visit to the Site, with particular reference to the sequence of pages viewed, the parameters relating to the operating system and the User’s computer environment.

Data Controller

The natural or legal person who decides how the personal data of the interested parties will be used. The data controller establishes the methods of use of users’ personal data and guarantees their protection together with the Head of Personal Data Protection (DPO).

Head of Personal Data Protection (DPO)

The natural or legal person who makes sure to protect the personal data of users, through the adoption of technical prevention measures and also through the adoption of internal codes of conduct.

Data Processor (or Manager)

The natural or legal person who is authorized by the Data Controller to process the Personal Data, to the processing of the personal data of the interested parties.

This Site

All the web pages of the site https://mmfirst.online that contain information and information content.

Cookie

Code fragment that collects data inside the device used by the user for navigation.

OWNER OF THE TREATMENT (DATA CONTROLLER) AND RESPONSIBLE FOR DATA PROTECTION

The data controller of this site is the company M&M First LLC. The contact details are:
– mail: support@mmfirst.online

The Data controllers of this site are (being updated)

REGULATORY SOURCES

COMPLIANCE WITH US PRIVACY LAWS

This Privacy Policy is compliant with applicable US federal and state privacy laws, including but not limited to:
– The California Consumer Privacy Act (CCPA)
– The California Privacy Rights Act (CPRA)
– The Virginia Consumer Data Protection Act (VCDPA)
– The Colorado Privacy Act (CPA)
– The Connecticut Data Privacy Act (CTDPA)
– The Utah Consumer Privacy Act (UCPA)

RECORDS OF PROCESSING ACTIVITIES

This website and the data controller have created the “Records of processing activities” in accordance with applicable US law requirements.

The “Records of processing activities” contains comprehensive information about data collection, processing purposes, categories of data subjects, and security measures implemented.

The “Records of processing activities” is in an electronic (digital) format and is stored in management software covered by cryptography not accessible by users and third parties.

In the event of a request for access by the competent Authorities in compliance with applicable laws, this website and the data controller will make the register available to the supervisory authority.

This website and the data controller have put in place adequate technical and organizational measures to guarantee an appropriate level of security to the risk in compliance with industry standards and best practices.

THEN WE INVITE YOU TO TAKE A VISION OF OUR ILLUSTRATED PRIVACY POLICY BELOW

PRIVACY POLICY

Data Communication

The personal data provided may be communicated to third parties in order to fulfill legal obligations, in execution of orders coming from public authorities legitimated to do so or to assert or defend a right in court.

Type of data processed and purpose of processing

Navigation data:

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the addresses in URI (Uniform resource Identifier), notation of the requested resources, the time of the request, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the status of the response given by the server (successful, error ….) and other parameters related to the operating system and the user’s computer environment. These data are used only to obtain anonymous statistical information on the use of the site and to control it.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could also be used to ascertain responsibility in case of hypothetical computer crimes against the site.

Data provided voluntarily by users / visitors:

In any occasion of contact with the site or during the completion of the information request form or to download the catalogues, our Company may collect additional personal information, for example, your contact information, type of user (professional/private), name and surname, email address, country and municipality of residence/ location, email address/telephone number. If the site allows the inclusion of comments, or in the case of specific services requested by the user, the site automatically detects and records some of the user’s identification data, including the email address. These data are voluntarily provided by the user at the time services are requested. By providing a comment or other information the user expressly accepts the privacy policy.

Personal data provided by users / visitors will be communicated to third parties only if the communication is necessary to comply with the requests of the users / visitors themselves.

Processing methods and data storage time

The Data are processed for the time necessary to perform the service requested by the User, or required by the purposes described in this document.

For newsletter subscriber: as soon as the user unsubscribe from the newsletter the personal data are completely eliminated from our management system.

For our clients: as soon as the consulting relationship with the customer is interrupted, personal data is kept for a period of 1 year.

Once the 1-year period has expired, the personal data of former clients or former employees are permanently deleted.

Security measures for data storage

This site and the company M&M First LLC observe specific security measures to prevent the loss of data, illicit or incorrect use and unauthorized access.

To guarantee the storage of data in conditions of maximum security, this website and the company M&M First LLC use software with encrypted technology, with access authentication.

This system prevents access to unauthorized parties and prevents the data collected from being read.

Optional supply of data and Refusal to provide

Apart from that specified for navigation data, users / visitors are free to provide their personal data. Failure to provide such data may only result in the impossibility of obtaining what is requested.

The interested party can refuse to give the Owner his navigation data. To do this, it must disable by following the instructions provided by the browser in use. Disabling cookies can make navigation of the site’s features worse.

Place of data processing

The processing operations connected to the web services of the website indicated above take place both at the headquarters of the company M&M First LLC and at the company headquarters and / or at the headquarters of the hosting and / or website management company and are only handled by technical staff of the office in charge of the processing, or by others in charge of occasional maintenance operations.

No data deriving from the web service is communicated or disseminated. The personal data provided by users who request dispatch of informative material are used only to perform the service or provision requested and are communicated to third parties only if this is necessary for that purpose.

Rights of concerned parties

The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or rectification.

Pursuant to applicable US privacy laws, the interested party has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose in any case, for legitimate reasons, to their treatment.

The subjects to whom the personal data refer have the right to:
– Withdraw consent to treatment;
– Obtain confirmation of the existence of personal data;
– Know who their data is transmitted to;
– Obtain the correction, deletion, integration of your data;
– Make a complaint to the relevant regulatory authorities;
– Know if the data is subject to profiling;
– Transfer your data to another supplier (portability right).

If you want to ask for more information on the processing of your data or if you want to exercise one of the rights mentioned above, you can send an email to the following address: support@mmfirst.online.

On what legal basis we treat your data

When we process your personal data for the purposes indicated in this Statement we base ourselves on one or more of the following legal bases:
– Consent: we ask for your consent to use your data, to update you on our content, to send you information about our services and for profiling (ie to analyze the interests and behavior of visitors to our site and to improve our marketing campaigns).
– Scope of contract: when you enter into a contract of any kind with us your personal data will be processed to pursue the purposes of the service you have purchased.
– Legal obligations: when strictly necessary, we will treat your personal data to comply with a legal obligation, an order imposed by the supervisory authority, a binding tax assessment.

NAVIGATION INFORMATION AND COOKIES (COOKIE POLICY)

What are cookies?

These are small text files sent from a website to the visitor and then sent back to the website to be read by the server, which allows specific information to be gathered about the visitor’s use of a particular site (how many pages and which pages he visited, how much time he stayed on the website, the channel through which he accessed the website etc.). This information is stored on the hard disk of the computer or on any device used by the user to

Cookies enable the website to be used, or they facilitate its operation or specific functionality. In a nutshell, they facilitate: storage of one’s preferences (language, font size, colour, etc.), avoiding the need to input the same information several times when accessing the site (login data), management of an e-commerce shopping cart, analysis of the visitor’s use of the services and the content provided by the site, viewing of content such as videos, maps etc., content-sharing on social networks, use of advertisements customised to users for a more effective advertising campaign.

We remind you that by proceeding with the navigation on this site or by clicking on the ok and X buttons on the banner of the brief information, you declare that you have read and accepted the privacy policy and the cookies policy, thereby consenting to the use of cookies present on this site.

The type of cookies we use

There are two types of cookies that are can use on our website: ‘session cookies’ e ‘persistent cookies’:
– temporary (or session) cookies have no expiry date and are removed at the end of the session or when the browser window is closed.
– persistent cookies have a predetermined expiry date, therefore they remain on the user’s computer even after the session has ended or the browser window is closed, so they can be read by the website that has just been visited on the next visit.

Type of cookies used on our webisite

Technical cookies

Technical cookies are those whose use does not require the user’s consent. These cookies are essential to allow you to browse a website and use all its features. Without these cookies, which are absolutely necessary, a website could not provide certain services or functions and browsing would not be as easy or easy as it should be. A cookie of this type is also used to store a user’s decision on the use of cookies on the website. Other technical cookies are those that allow, for example, the saving of preferences related to the language or shopping cart.

WordPress cookies

This site was developed on the wordpress platform, so it uses cookies implemented by the aforementioned platform. The cookies stored concern those who have registered an account on the wordpress blog and those who comment on the articles.

WordPress cookies are:
– wordpress_[hash]
– wordpress_logged_in_[hash]
– wp-settings- {time}-[UID]
– cookie_notice_accepted (is the cookie used to store a user’s decision about the use of cookies on the website)

All these cookies are persistent and are released to ensure a better browsing experience on this site.

Profiling Cookies

This site uses cookies of this type. Advertising cookies are installed to show site visitors content related to their preferences. They can then be used to show advertising content aimed at the interests of the person. Cookies of this type work in collaboration with third-party sites and can track past browsing on pages and different domains. Cookies of this type usually track the user’s IP address as well as other information, some of which may be personal.

Third-party cookies

These cookies are used to collect information on the use of the site made by users in anonymous form such as: visited pages, time spent, origins of traffic of origin, geographical origin, age, gender and interests for statistical purposes and marketing campaigns. These cookies are sent from third-party domains external to the site.

Google analytics cookies with anonymized IP

Our pages use Google Analytics third-party performance cookies with anonymized IP (service offered by Google, Inc.) to allow us to collect anonymously and examine visitor behavior while using the site and to improve its usability and user experience. They are defined as anonymous because they cannot be used to identify specific individuals.

Through the use of the Google Analytics panel, it is possible to understand whether the visits were made by new or returning visitors, verifying the way in which the pages were browsed (input, exit links, page shifts, residence times, geographical origin, etc.).

For more information about Google Analytics, you can visit the sites:

https://www.google.it/policies/privacy/partners/

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

It is possible to disable the action of Google Analytics through the tools provided by Google. For information on this, consult the site:

https://tools.google.com/dlpage/gaoptout

Cokies used by da Google Analytics are:
– _ga (persistent – 2 years)
– _utma (persistent – 2 years)
– __utmb (session)
– __utmt (session)
– __utmz (session)
– _gat (persistent – 10 minutes)

How to check and disable cookies

Most browsers are configured to accept, control or possibly disable cookies through the settings. For more information on managing cookies, visit the appropriate links:
– Internet explorer
– Chrome / windows phone
– Safari/ IOS
– Firefox

For more information on cookies and to manage cookie preferences (first and / or third party) you can also visit the platform www.youronlinechoices.com.

Social network buttons and widgets

To ensure that the contents of a site can be shared on social networks by site visitors, it is possible to integrate in the pages the tools (widgets) made available to the social networks themselves.

These tools (usually blocks of code inserted in the pages of the host site) can collect third-party cookies installed by social networks (for example Facebook, Twitter, YouTube, etc.); the site does not share any information with these widgets.

To get more information about the cookies of the main social networks, you can visit the sites:
– Privacy Facebook
– Privacy Instagram
– Privacy Youtube
– Privacy Twitter
– Privacy LinkedIn
– Privacy Pinterest
– Privacy Whatsapp
– Privacy Telegram

Consent to the use of Cookies (Cookie Consent)

We remind you that if you do not consent to the use of cookies and decide to disable the cookies we use, this may affect your user experience while you visit our site (preventing you from seeing certain parts or some web pages).

SAFETY PROTOCOLS

This website uses the secure communication protocol “https” (Hypertext Transfer Protocol Secure).

The “https” protocol is used to ensure secure communication between two IT devices connected to the internet network.

In this way, if you fill in one of the contact forms on our site, your message will be transmitted within an encrypted connection, using asymmetric cryptography (though protocols TLS – Transport Layer Security e SSL – Secure Sockets Layer).

The “https” protocol guarantee:

– authentication of the website visited;

– the protection of privacy (confidentiality or confidentiality);

– the integrity of the data exchanged between the communicating parties.

We use the “https” protocol to protect your data through a two-way encryption of communications between a client and a server.

This allows us to protect your data from possible operations of:

– eavesdropping à action by which the private conversation between the parties without their consent is secretly intercepted;

– opertampering à literally “tampering or alteration of communication”, an action by which the contents of a web communication are falsified.

So, the “https” protocol guarantees that:

– the user is communicating exactly with the desired website (as opposed to a fake site);

– the contents of the communications between the user and the website cannot be intercepted or altered by third parties.

PROFILING AND MARKETING ACTIVITIES

The M&M First LLC company, through this website, carries out marketing and profiling activities.

Marketing and profiling activities are carried out only for persons who have expressed their consent to the processing of personal data.

The marketing activities are aimed at making known the services and contents realized by the company M&M First LLC to the interested persons who have given their consent to the processing of data.

The profiling activities are carried out to measure the results of marketing campaigns; these activities consist in collecting and processing the data of the users interested in a service to divide them into groups based on their behavior.

To carry out marketing and profiling activities, the company M&M First LLC uses the following tools.

Facebook Pixel

This website uses a script called “Facebook Pixel”.

We use this tool to collect statistical data that allows us to measure the effectiveness of paid advertising.

Thanks to Facebook Pixel we can understand the actions that people perform on our website. The data we collect is used to:
– Ensure that advertisements are shown to the right people;
– Create audience groups to target advertisements;
– Take advantage of additional advertising tools on the platform on which we advertise.

We use Facebook Pixel to carry out “remarketing” and “retargeting” activities; thanks to these activities we use cookies that you leave on our site, without identifying yourself. In this way your navigation data are not linked to your identity and your personal data.

The data collected thanks to Facebook Pixel are used only by us and by external professionals who support us in marketing and online advertising.

Google Tag Manager

This type of service is functional to the centralized management of the tags or scripts used on this Website.

The use of these services involves the flow of User Data through them and, if necessary, their retention.

Google Tag Manager is a tag management service provided by Google LLC.
– Personal Data collected: Cookies and usage data.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and to interact with them.

In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.

Video Vimeo (Vimeo, LLC)

Vimeo is a video content visualization service managed by Vimeo, LLC which allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy.

Widget Video YouTube (Google Ireland Limited)

YouTube is a video content viewing service operated by Google Ireland Limited that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: Ireland– Privacy Policy. Subject adherent to the Privacy Shield.

Newsletter and email marketing software

If you decide to subscribe to our newsletter, we will ask you to enter your personal data (name, surname, email) in a contact form.

We will use your personal information to send you emails that will update you about our content (Blog articles, videos, etc.).

If you decide to receive “updates on our services”, we will use your information to send you emails explaining to you if our services may be useful to you.

When you enter your details in the contact form, the data will end up in an “email marketing” software called AWeber.

Access to the AWeber software is covered by “end to end” encryption; to access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account.

The data collected on AWeber are consulted only by us and by external professionals who support us in email marketing activities.

You can choose at any time to unsubscribe from our newsletter; to unsubscribe you can click on a specific button that you will find in our emails.

After clicking on the delete button, your data will be deleted immediately from the “email marketing” software.

Crisp

To manage our newsletter, publish our content, communicate our commercial offers, and better assist our customers, we use a chat software called Crisp.

Our Crisp collects your personal data entered within the chat (name, surname, email) which we will then use to send you our newsletters in the future.

We will use your personal data to send you emails that will contain updates on our content (Blog articles; Podcast episodes; videos; communications about our services).

When you agree to sign up for Crisp, your personal data entered on Crisp (name, surname, email) will end up in an external software listed above.

Access to Crisp software is covered by “end to end” encryption.

To access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account.

The data collected on Crisp are consulted only by us and by external professionals who support us in email marketing activities.

SERVICES

In this section we will explain how we use your data if you request one of our services.

M&M First LLC Services

When you request one of the services of M&M First LLC we use the data you have entered in the contact form to respond to your requests and to provide you with the service you have chosen.

To protect your data, we use pre-defined processing procedures and follow an internal code of conduct; in this way we protect your data securely.

In the processing of data we could use:

– tools, applications or cloud storage services;

– e-mail tools, applications or services;

– tools, applications or data transfer services such as Wetransfer.

These activities may involve the transfer of data on servers located outside the United States, regardless of our wishes.

To carry out our services we use these software: Gmail, Google Drive, Google Calendar, Evernote, Dropbox, Slack, Zapier.

We invite you to consult the privacy policy of these programs by clicking on these pages:
– Gmail
– Google Drive
– Google Calendar
– Google Privacy Policy
– AWeber
– Dropbox
– Slack
– Zapier
– Typeform
– Youtube
– ClickFunnels
– Crisp

If you request one of the services of M&M First LLC your personal data will be communicated to third parties only when it is necessary for the processing of your file.

The subjects to whom we can communicate your personal data are:
– Internal staff and collaborators of M&M First LLC who will be in charge of processing your project;
– External Web Agencies that collaborate with us for the realization of your project;
– External professionals who will be in charge of processing your project;
– External accounting professionals who work with us for the accounting management of our company;

Online training and video training services

When you buy one of the video courses and / or subscriptions of M&M First LLC the data you entered to complete the payment will end up in a software called “Paypal”.

Access to Paypal software is covered by “end to end” encryption.

To access the software we use a double authentication procedure; this tool prevents third parties from accessing the data in our account.

The data collected on Paypal are consulted only by us and by external professionals who support us in marketing activities.

You can choose at any time to cancel your data on Paypal by canceling your registration on Paypal.com.

User rights

The subjects to whom the data refer have the right at any time to obtain confirmation of the existence of the same from the Data Controller, to know the content and origin, to verify its accuracy or request its integration, the cancellation, updating, rectification, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their treatment and in any case have all the rights specified in applicable US privacy laws.

The request must be addressed to the Owner at the email address: support@mmfirst.online

In order to contribute to the management costs for this request, we ask the user to pay a fee of $10.