Personal Data processed for the following purposes and using the following services:

• • Advertising

    • Playrcart, GRAPHINIUM, Query Click, Videobyte, Videology, Google Ad Manager, Video Reach and Jetpack

      Personal Data: Tracker; Usage Data

  • Analytics

    • Google Analytics, Google Analytics with anonymized IP and Wordpress Stats

      Personal Data: Tracker; Usage Data

    • Google Analytics Advertising Reporting Features

      Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service

    • Google Analytics Demographics and Interests reports

      Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)

    • Simple Analytics

      Personal Data: device information; language; Usage Data

  • Contacting the User

    • Contact form

      Personal Data: city; country; date of birth; email address; first name; gender; last name; phone number; physical address; state; Tax ID; User ID; various types of Data; VAT Number; ZIP/Postal code

    • Mailing list or newsletter

      Personal Data: email address

  • Content performance and features testing (A/B testing)

    • Google Optimize and Google Optimize 360

      Personal Data: Tracker; Usage Data

  • Data transfer outside of the UK

    • Data transfer abroad based on consent (UK), Data transfer abroad based on standard contractual clauses (UK) and Data transfers according to a UK adequacy regulation

      Personal Data: various types of Data

  • Data transfer outside the EU

    • Data transfer abroad based on consent

      Personal Data: various types of Data

  • Displaying content from external platforms

    • Google Fonts

      Personal Data: Tracker; Usage Data

  • Handling activities related to productivity

    • Gmail and Google Workspace

      Personal Data: Data communicated while using the service; email address; first name; last name; profile picture

  • Handling payments

    • Wyre

  • Hosting and backend infrastructure

    • Amazon Web Services (AWS)

      Personal Data: various types of Data as specified in the privacy policy of the service

    • iubenda Consent Solution

      Personal Data: Data communicated while using the service; Tracker

  • Interaction with data collection platforms and other third parties

    • ConvertKit widget

      Personal Data: email address; first name; Tracker; Usage Data

  • Interaction with external social networks and platforms

    • Facebook Like button and social widgets, Reddit button and widgets and Twitter Tweet button and social widgets

      Personal Data: Tracker; Usage Data

    • YouTube button and social widgets

      Personal Data: Usage Data

  • Location-based interactions

    • Non-continuous geolocation

      Personal Data: geographic position

  • Managing contacts and sending messages

    • ConvertKit

      Personal Data: email address; first name; Tracker; Usage Data

  • Registration and authentication provided directly by Hot Drops Inc.

    • Direct registration

      Personal Data: email address; first name; last name; password; User ID

  • Remarketing and behavioral targeting

    • Google Ad Manager Audience Extension

      Personal Data: Tracker; Usage Data

  • Tag Management

    • Google Tag Manager

      Personal Data: Tracker; Usage Data

  • Traffic optimization and distribution

    • Cloudflare

      Personal Data: Tracker; various types of Data as specified in the privacy policy of the service

    • Sucuri CloudProxy

      Personal Data: various types of Data as specified in the privacy policy of the service

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

• • iubenda Consent Solution localStorage

    iubenda ConS JS library localStorage (IUB_DATA) temporarily stores pending data in a storage space internal to the User's browser (localStorage) until it's received by the API, then it is deleted.

  • iubenda Cookie Solution (consent Cookie)

    iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers in the local domain.

  • iubenda Cookie Solution (remote consent Cookie)

    Remote iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers under the .iubenda.com domain.

  • iubenda CCPA Cookie (usprivacy)

    iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain.

  • Analysis and predictions based on the User’s Data (“profiling”)

    The Owner may use the Personal and Usage Data collected through Hot Drops Inc. 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.

  • Automated decision-making

    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Hot Drops Inc. may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Hot Drops Inc. adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s 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 the 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 User's 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 Hot Drops Inc, 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 User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

  • Browser Fingerprinting

    Browser Fingerprinting creates an identifier based on a device's unique combination of characteristics (e.g. IP address, HTTP header, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User's browsing behavior across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.

  • Global TCF v2 Cookie (euconsent-v2)

    Global TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences under the .consensu.org domain. When a Global TCF v2 Cookie (euconsent-v2) is set by the iubenda Cookie Solution, also a local 'cache' Cookie is stored in the local domain.

  • localStorage

    localStorage allows Hot Drops Inc. to store and access data right in the User's browser with no expiration date.

  • Personal Data collected through sources other than the User

    The Owner of Hot Drops Inc. may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
    Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

  • Preference Cookies

    Preference Cookies store the User preferences detected on Hot Drops Inc. in the local domain such as, for example, their timezone and region.

  • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Hot Drops Inc. depends on the payment system used.

  • sessionStorage

    sessionStorage allows Hot Drops Inc. to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).

  • Site specific TCF v2 Cookie (euconsent-v2)

    Site specific TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences in the local domain.

  • The Service is intended for adults

    Users declare themselves to be adult according to their applicable legislation. Minors may not use Hot Drops Inc.

  • The Service is not directed to children under the age of 13

    Users declare themselves to be adult according to their applicable legislation. Minors may use Hot Drops Inc. only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Hot Drops Inc.

  • Transfer of personal information outside of Brazil based on your consent

    We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
    When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
    Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
    You may withdraw your consent at any time.

  • Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD

    We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
    The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

    • the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
    • the nature of the personal information subject to the transfer;
    • the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
    • the adoption of suitable security measures;
    • the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
    • any other pertinent circumstance related to the relevant transfer.

  • 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.

Contact information

• • Owner and Data Controller

    Hot Drops Inc.
    % Registered Agents Inc.
    8 The Grn Ste R
    Dover, DE 19901

    Owner contact email: legal@myhotdrops.com