Welcome to the privacy policy of AthletEye. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Latest update: February 21, 2026
Summary
Data we collect automatically
We automatically collect data from you for example when you visit AthletEye.
Registration and authentication provided directly by this Application
Social features
Managing data collection and online surveys
Spam and bots protection
Owner and Data Controller
Mesut Yilmaz
Owner contact email: athleteye@gmail.com
Type of Data we collect
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Trackers
Usage Data
device information
geography/region
number of sessions
session duration
Application opens
operating systems
first name
phone number
email address
username
password
profile picture
page views
IP address
browser information
various types of Data
Camera permission
Precise location permission (continuous)
Precise location permission (non-continuous)
Approximate location permission (continuous)
Approximate location permission (non-continuous)
Photo Library permission
Camera permission, without saving or recording
payment info
last name
purchase history
geographic position
precise location
coarse location
date of birth
country
User ID
picture
city
answers to questions
clicks
keypress events
motion sensor events
mouse movements
scroll position
touch events
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 this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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 this Application or by the owners of third-party services used by this Application 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.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
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 this Application (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.
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.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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:
Analytics
Registration and authentication
Hosting and backend infrastructure
Managing contacts and sending messages
Infrastructure monitoring
Content performance and features testing (A/B testing)
Collection of privacy-related preferences
Data transfer outside of the UK
Data transfer outside the EU
Device permissions for Personal Data access
Platform services and hosting
Handling payments
Location-based interactions
Registration and authentication provided directly by this Application
Social features
Managing data collection and online surveys
Spam and bots protection
Detailed information on the processing of Personal Data
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics for Firebase (for apps)
Company: Google LLC
Place of processing: United States
Personal Data processed: Application opens +7
Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
geolocation data
Collection of privacy-related preferences
This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
Cookie Notice & Compliance for GDPR/CCPA
Company: Hu-manity Rights, Inc.
Place of processing: United States
Personal Data processed: browser information +4
Cookie Notice & Compliance for GDPR/CCPA is website banner provided by Hu-manity Rights, Inc. that helps this Application comply with cookie consent requirements.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.
Firebase Remote Config
Company: Google LLC
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access
Personal Data processed: Approximate location permission (continuous) +6
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed:
Approximate location permission (continuous)
Approximate location permission (non-continuous)
Camera permission
Camera permission, without saving or recording
Photo Library permission
Precise location permission (continuous)
Precise location permission (non-continuous)
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
geolocation data
Handling payments
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Payments processed via the Apple App Store
Company: Apple Inc.
Place of processing: United States
Personal Data processed: device information +8
This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
RevenueCat
Company: RevenueCat, Inc.
Place of processing: United States
Personal Data processed: Trackers +2
RevenueCat is a payment service provided by RevenueCat, Inc. The service allows the Owner to monitor and analyze the User and their purchase history and can be used to keep track of User behavior.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Firebase Cloud Firestore
Company: Google LLC
Place of processing: United States
Personal Data processed: Usage Data +1
Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.
Personal Data processed:
Usage Data
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Firebase Performance Monitoring
Company: Google LLC
Place of processing: United States
Personal Data processed: Trackers +1
Firebase Performance Monitoring is a monitoring service provided by Google LLC.
Personal Data processed:
Trackers
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Location-based interactions
Geolocation
Personal Data processed: coarse location +2
This Application 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 this Application.
Personal Data processed:
coarse location
geographic position
precise location
Category of Personal Information collected according to the CCPA
geolocation data
Non-continuous geolocation
Personal Data processed: coarse location +1
This Application 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 this Application.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed:
coarse location
geographic position
Category of Personal Information collected according to the CCPA
geolocation data
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.
Firebase Cloud Messaging
Company: Google LLC
Place of processing: United States
Personal Data processed: Trackers +1
Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed:
Trackers
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Firebase Notifications
Company: Google LLC
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Data provided via online forms, managed directly
Company: this Application
Personal Data processed: city +8
This Application makes use of online forms that can be used to collect Data about Users.
Personal Data processed:
city
country
date of birth
email address
payment info
phone number
profile picture
Trackers
Usage Data
Service provided by:
this Application
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
audio, electronic, visual, thermal, olfactory, or similar information
Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Play Store
Company: Google LLC
Place of processing: United States
Personal Data processed: Usage Data
This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
App Store Connect
Company: Apple Inc.
Place of processing: United States
Personal Data processed: Trackers +1
This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage this Application on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of this Application.
App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Registration and authentication
By registering or authenticating, Users allow this Application 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, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Firebase Authentication
Company: Google LLC
Place of processing: United States
Personal Data processed: email address +5
Firebase Authentication is a registration and authentication service provided by Google LLC.
To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Category of Personal Information collected according to the CCPA
identifiers
audio, electronic, visual, thermal, olfactory, or similar information
Sign in with Apple
Company: Apple Inc.
Place of processing: United States
Personal Data processed: email address +2
Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
User Account Management
Company: this Application
This service manages the User’s account and identity records within AthletEye. It processes the Firebase User ID and, where available, basic account information such as display name, profile photo URL, email address, and phone number. It also stores account security and lifecycle data including email verification status, account creation date, last sign-in time, last activity time, and last logout time.
Where applicable, the service may process account status information (e.g., active or restricted) and temporary restriction details (e.g., ban duration). If the User provides it or it is required by law, the service may also record age-related confirmations such as an 18+ declaration and the time of age verification.
These data are used to operate and secure the account, support sign-in and session management, enforce platform rules, prevent abuse, and maintain service integrity.
Registration and authentication provided directly by this Application
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration
Personal Data processed: country +9
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed:
country
date of birth
email address
first name
last name
phone number
profile picture
Usage Data
User ID
various types of Data
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
audio, electronic, visual, thermal, olfactory, or similar information
Social features
Public profile
Personal Data processed: city +7
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.
Personal Data processed:
city
country
date of birth
email address
first name
last name
picture
username
Category of Personal Information collected according to the CCPA
identifiers
audio, electronic, visual, thermal, olfactory, or similar information
Inviting and suggesting friends
Personal Data processed: various types of Data
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed:
various types of Data
Category of Personal Information collected according to the CCPA
identifiers
Spam and bots protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Google reCAPTCHA
Company: Google LLC
Place of processing: United States
Personal Data processed: answers to questions +8
Google reCAPTCHA is a spam protection service provided by Google LLC.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
inferences drawn from other personal information
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Player Profile and Stats
This service creates and manages the User’s in-app player profile. To create the profile during onboarding, it processes the User’s account identifier (Firebase User ID), a unique player name, and date of birth. Only the player name and date of birth are mandatory to complete onboarding; all other profile fields are optional and are processed only if the User chooses to provide or update them later.
The service may also process optional profile information such as a profile photo URL, biography, nationality, physical attributes (height and weight), preferred foot, shirt number, and playing positions. In addition, the service may process performance-related data (user-generated or app-generated) such as goals, assists, matches played, and similar statistics.
These data are used to display and maintain the player profile, enable team-based interactions, and provide performance insights (e.g., personal statistics summaries, trend analysis, and comparisons over time). In future versions, the service may also assign achievement indicators (such as badges or skill tiers—e.g., Rookie, Amateur, Skilled, Professional) based on the User’s activity or profile information.
Data Collected List
1.Account Identifier (required) Firebase User ID used to uniquely identify the User’s player profile.
2.Player Name (required) Unique in-app player name selected by the User during onboarding.
3.Date of Birth (required) Used to create the player profile and support age-related features where applicable.
4.Profile Photo URL (optional) Link to the User’s profile image stored in the App’s storage infrastructure.
5.Biography (optional) Short self-description provided by the User.
6.Nationality (optional) Country/region information provided by the User.
7.Physical Attributes (optional) Height and weight information provided by the User.
8.Preferred Foot (optional) Left/right/both (or similar) preference provided by the User.
9.Shirt Number (optional) Number provided by the User for profile display.
10.Playing Positions (optional) Main position and additional/detail positions selected by the User.
11.Performance Statistics (optional / user-generated or app-generated) Data such as goals, assists, matches played, and similar activity/performance metrics.
12.Profile Metadata (optional / app-generated) Record management details such as creation/update timestamps and internal identifiers used to keep the profile consistent (where implemented).
Team Events and Participation Management
This service enables the creation, organisation, and coordination of team-based sports events within the App. It processes event details such as participating team names, match format, formation or lineup settings, and scheduling information (date and time).
Where the User chooses to add it, the service may process event location information. If location-based features are enabled, it may use the event’s location and/or the User’s current position at the time of creation to support proximity-based filtering and to help Users find events near them. Location processing depends on the User’s device permissions and settings.
The service also manages participation information to track attendees and their status (e.g., in/out/pending), along with relevant metadata such as timestamps and unique identifiers. User-provided notes, descriptions, and requirements may be processed to support communication between event organisers and participants and to ensure consistent event management in the App.
Data Collected List
1. Event Location (required) & Proximity Filters Required venue location for the event; may also support distance-based filtering and “nearby events” features.
2. Event Schedule & Timing Event date, start time, and (if applicable) end time/duration.
3.Match & Team Details Team names, match format, formation/lineup configuration, and related event settings.
4.Participation & Attendance Status Attendee list and participation state (e.g., in/out/pending), including RSVP updates.
This service creates and manages team entities within the App. It processes team identification data (Team ID), team profile information (team name and sport type), and creator information (creator identifier and creation timestamp) to establish and operate teams on the platform.
The service also processes governance and role-based information—such as the admin list and captain identifier—to support team administration, permissions, and in-app controls. Where provided by the User, it may process team presentation and branding details (e.g., logo URL, banner URL, biography, and team colour) to display the team profile within the App.
To enable team invitations and controlled access, the service processes an invite code. Where applicable, it may process team address/location information to support team discovery, local features, or event coordination. The service may also store aggregated or derived team metrics (e.g., average age and member count) for display and operational purposes.
Where team chat features are enabled, the service may process security-related key metadata (such as an encrypted chat key reference and key version) to support secure team messaging. Such security data is used to maintain confidentiality and integrity of communications, where implemented.
Data Collected List
1.Team Identifier (required) Team ID used to uniquely identify the team record.
2.Team Profile Details (required) Team name and sport type.
3.Creator & Creation Metadata (required) Creator identifier (e.g., Firebase User ID) and creation timestamp.
4.Team Governance & Roles (required) Admin list and captain identifier used for permissions and role-based controls.
5.Team Address / Location (optional, where applicable) Address/location information associated with the team (depending on features enabled).
6.Team Branding & Presentation (optional) Logo URL, banner URL, biography, and team colour.
7.Invitation & Access Data (required) Invite code used for team invitations and controlled access.
8.Team Aggregates / Derived Metrics (optional / app-generated) Average age and member count (and similar aggregated values), where implemented.
9.Chat Security Metadata (optional / security-related) Encrypted chat key reference (e.g., key material in encrypted/encoded form) and key version used for secure messaging features, where enabled.
Team Messaging and Chat History
This service enables real-time communication and coordination between team members within the App. It processes user-generated content, including message text and any media shared through the chat (such as images and audio), in order to deliver in-app messaging features.
To support group messaging functionality, the service processes sender information (such as sender identifiers and profile display details) and interaction data associated with messages, including read receipts (e.g., seen-by information), replies, reactions, and message status. It also processes technical identifiers and timestamps to maintain message delivery, ordering, and synchronisation across devices.
The service supports message lifecycle actions such as edits, deletions (including “deleted for” states), and system-generated chat events (where applicable). Where secure messaging features are implemented, the service may process encryption-related status indicators and key/version references to help maintain the confidentiality and integrity of team communications. These data are used to provide a persistent and functional chat history for Users and to ensure the reliable operation of chat features.
Data Collected List
1.Communication Content (user-generated) Message text; image URL; audio URL (and similar chat content shared by the User).
2.Interaction Data (user-generated and/or app-generated) Reactions; seen-by/read receipt information; reply references (e.g., reply-to message); message status indicators.
3.Sender Identity (required for messaging) Sender identifier (e.g., senderId); sender display name (senderName); sender avatar/profile image URL (senderAvatarUrl), where available.
4.Message Lifecycle & Record Metadata (app-generated and/or user-triggered) Message identifier (messageId); edit state (isEdited); update timestamps (updatedAt); deletion state and scope (deletedFor); related audit/consistency metadata where implemented.
5.Technical & Security Status Indicators (optional, where implemented) Encryption status indicator (isEncrypted); system event type (systemEventType); and related delivery/synchronisation identifiers/timestamps necessary to operate chat features.
Push notifications based on the User's geographic location
This Application may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application 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.
Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Push notifications for direct marketing
This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on Users, is taken solely by technological means, without any human intervention.
This Application may use the Users' Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between Users and Owner, or on the basis of the Users' 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 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 Users' 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 this Application, 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 Users' rights and the means to exercise them, Users are invited to consult the section of this document relating to the rights of Users.
Equal protection of User Data
This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
The Service is intended for adults
Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
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.
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.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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 fulfil 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 rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
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.
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 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 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.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including 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.
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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer to countries that guarantee European standards
If this is the condition for Data transfer, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Data transfer abroad based on standard contractual clauses
If this is the condition for Data transfer, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Transfer of Personal Data outside of the United Kingdom
Data transfers according to a UK adequacy regulation
If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.
The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).
Data transfer abroad based on standard contractual clauses (UK)
If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
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. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Additional information for Users in Brazil
Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.
To do so, we may use one of the following legal means:
specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Identifiers
Personal Data processed: Various types of data as specified in the privacy policy of the service; First name; Phone number; Email address + 12
Personal Information collected or disclosed:
various types of Data as specified in the privacy policy of the service
first name
phone number
email address
profile picture
Usage Data
Trackers
various types of Data
last name
device information
purchase history
date of birth
country
User ID
picture
city
Sensitive Personal Information collected or disclosed
username, password, payment info
Purposes:
Further information about Personal Data
Registration and authentication
Hosting and backend infrastructure
Managing contacts and sending messages
Infrastructure monitoring
Content performance and features testing (A/B testing)
Data transfer outside of the UK
Data transfer outside the EU
Handling payments
Registration and authentication provided directly by this Application
Social features
Managing data collection and online surveys
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
Google LLC, this Application, Apple Inc., RevenueCat, Inc.
Service providers or contractors:
this Application
Internet or other electronic network activity information
Personal Data processed: Trackers; Usage data; Device information; Geography/region + 31
Personal Information collected or disclosed:
Trackers
Usage Data
device information
geography/region
number of sessions
session duration
Application opens
operating systems
various types of Data as specified in the privacy policy of the service
page views
IP address
browser information
Camera permission
Approximate location permission (continuous)
Approximate location permission (non-continuous)
Photo Library permission
Camera permission, without saving or recording
first name
last name
email address
purchase history
date of birth
phone number
country
profile picture
User ID
various types of Data
city
answers to questions
clicks
keypress events
motion sensor events
mouse movements
scroll position
touch events
Sensitive Personal Information collected or disclosed
To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information for Users in the United States
Profiling of Users in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
We perform automated processing of your Personal Information to evaluate, analyze, or predict personal aspects related to, for example, your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Such profiling activity is done in furtherance of decisions that may result in the provision or denial of, for example, financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, healthcare services, or access to essential goods or services.
You always have the right to opt out from this kind of profiling activity. To fully exercise this right to opt out you can contact us at any time, using the contact details provided in this document.
To find out more about your rights and how to exercise them, you can consult the“Your privacy rights under US state laws” section of this document.
We do not collect Personal Information about children in the United States
We do not knowingly collect Personal Information of children nor do we Sell or process their Information for Targeted Advertising purposes.
We do not collect Personal Information about children under the age of 13 in the United States
We do not knowingly collect Personal Information of children under the age of 13 nor do we Sell or process their Information for Targeted Advertising purposes.
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 this Application 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, this Application 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, this Application and any third-party services may collect files that record interaction with this Application (System logs) or 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.
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 this Application 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.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to this Application, if not stated otherwise within this document.
