Owner and Data Controller
Photoventura SA
150 mt este del Hotel Flor del Itabo
50503 Playas del Coco
Guanacaste (Costa Rica)
Owner contact email: info@photoventura.net
Types of Data collected
Among the types of Personal Data that photoventura.info collects, by itself or through third parties, there are:
Usage Data; Trackers; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; first name; last name; phone number; physical address; country; state; email address; ZIP/Postal code; various types of Data; city; Data communicated while using the service; calendar information; device information; name; geographic position; Universally unique identifier (UUID); personal data collected from a known child; gender; date of birth; profile picture; session statistics; browser information.
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 photoventura.info.
Unless specified otherwise, all Data requested by photoventura.info is mandatory and failure to provide this Data may make it impossible for photoventura.info to provide its services. In cases where photoventura.info 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 photoventura.info or by the owners of third-party services used by photoventura.info 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 photoventura.info.
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 photoventura.info (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:
SPAM protection, Displaying content from external platforms, Contacting the User, Interaction with external social networks and platforms, Analytics, Data transfer outside of the UK, Collection of privacy-related preferences, Data transfer outside the EU, Traffic optimization and distribution, Managing contacts and sending messages, Interaction with data collection platforms and other third parties and Tag Management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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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 (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of photoventura.info, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Google Analytics (Universal Analytics) with anonymized IP (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of photoventura.info, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of photoventura.info, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: browser information; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Collection of privacy-related preferences
This type of service allows photoventura.info to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Database (iubenda srl)
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on photoventura.info.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Contacting the User
Contact form (photoventura.info)
By filling in the contact form with their Data, the User authorizes photoventura.info to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: city; country; email address; first name; last name; phone number; physical address; state; various types of Data; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Mailing list or newsletter (photoventura.info)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning photoventura.info. Your email address might also be added to this list as a result of signing up to photoventura.info or after making a purchase.
Personal Data processed: city; country; email address; first name; last name; phone number; physical address; state; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of photoventura.info and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Calendly widget (Calendly, LLC)
Calendly widget is a calendar content visualization service provided by Calendly, LLC that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: calendar information; device information; email address; geographic position; name; phone number.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data.
This processing constitutes:
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube video widget (Privacy Enhanced Mode) (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows photoventura.info to incorporate content of this kind on its pages.
This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on photoventura.info unless they play the video.
Personal Data processed: Trackers; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows photoventura.info to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of photoventura.info for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Typeform widget (TYPEFORM S.L)
The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.
Personal Data processed: city; country; Data communicated while using the service; date of birth; email address; first name; gender; last name; phone number; physical address; profile picture; state.
Place of processing: Spain – Privacy Policy.
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.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of photoventura.info.
The interaction and information obtained through photoventura.info are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on photoventura.info isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Meta Platforms, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
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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.
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: country; email address; first name; last name; phone number; various types of Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
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SPAM protection
This type of service analyzes the traffic of photoventura.info, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google LLC)
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.
This processing constitutes:
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on photoventura.info in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Traffic optimization and distribution
This type of service allows photoventura.info to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between photoventura.info and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through photoventura.info, i.e., communication between photoventura.info and the User's browser, while also allowing analytical data from photoventura.info to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Further information about the processing of Personal Data
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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 photoventura.info depends on the payment system used.
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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.
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Equal protection of User Data
Photoventura.info 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.
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localStorage
localStorage allows photoventura.info to store and access data right in the User's browser with no expiration date.
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Personal Data collected through sources other than the User
The Owner of photoventura.info 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.
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Preference Cookies
Preference Cookies store the User preferences detected on photoventura.info in the local domain such as, for example, their timezone and region.
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Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on photoventura.info, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
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sessionStorage
sessionStorage allows photoventura.info 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).
Cookie Policy
Photoventura.info uses Trackers. To learn more, Users may consult the Cookie Policy.
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 abroad based on standard contractual clauses
If this is the legal basis, 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 transfer abroad based on standard contractual clauses (UK)
If this is the legal basis, 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.
Other legal basis for Data transfer abroad (UK)
If no other legal basis applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
- the data transferred is sourced from a public register created under UK law;
- subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via photoventura.info.
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 photoventura.info 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.
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.
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 photoventura.info 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 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 Information collected or disclosed:
various types of Data as specified in the privacy policy of the service, first name, last name, phone number, physical address, country, state, email address, ZIP/Postal code, various types of Data, city, calendar information, device information, name, geographic position, Usage Data, Trackers, Universally unique identifier (UUID), personal data collected from a known child, gender, date of birth, profile picture, Data communicated while using the service
Purposes:
- Further information about Personal Data
- Contacting the User
- Data transfer outside of the UK
- Data transfer outside the EU
- Displaying content from external platforms
- Traffic optimization and distribution
- Managing contacts and sending messages
- Interaction with data collection platforms and other third parties
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Calendly, LLC, Google LLC, Cloudflare Inc., Intuit Inc., TYPEFORM S.L
Service providers or contractors: photoventura.info
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
Usage Data, Trackers, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, Data communicated while using the service, calendar information, device information, email address, name, phone number, geographic position, Universally unique identifier (UUID), first name, last name, gender, date of birth, physical address, country, state, profile picture, city, session statistics, browser information
Purposes:
- SPAM protection
- Displaying content from external platforms
- Interaction with external social networks and platforms
- Analytics
- Collection of privacy-related preferences
- Further information about Personal Data
- Interaction with data collection platforms and other third parties
- Tag Management
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC, Meta Platforms, Inc., iubenda srl, Calendly, LLC, Vimeo, LLC, TYPEFORM S.L, Fonticons, Inc.
Service providers or contractors: photoventura.info
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
Usage Data, Trackers, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
-
Geolocation data
Personal Information collected or disclosed:
calendar information, device information, email address, name, phone number, geographic position
Purposes:
- Displaying content from external platforms
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Calendly, LLC
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
first name, last name, gender, date of birth, phone number, physical address, email address, country, state, profile picture, city, Data communicated while using the service
Purposes:
- Interaction with data collection platforms and other third parties
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: TYPEFORM S.L
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and 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.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” 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 photoventura.info.
For example, you directly provide your Personal Information when you submit requests via any forms on photoventura.info. You also provide Personal Information indirectly when you navigate photoventura.info, 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 photoventura.info 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 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 and Oregon, 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.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, 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 photoventura.info.
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
Collection of personal information about California consumers below the age of 13
We collect personal information of consumers below the age of 13 and won't sell or share their personal information unless their parents or guardians have opted in on behalf of those minors.
Collection of personal information about California consumers aged 13 to 16
We collect personal information of consumers between the age of 13 and 16 and won't sell or share their data personal information unless those consumers have opted in.
Collection of personal data about Virginia consumers below the age of 13
We collect, use, or disclose personal data of Virginia consumers below the age of 13 only if we have obtained verifiable parental consent to do so.
We do not collect personal data about Virginia consumers below the age of 13
We do not knowingly collect personal data of Virginia consumers who are below the age of 13 nor do we sell their data or process them for targeted advertising purposes.
We do not collect personal information about California consumers below the age of 16
We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.
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 photoventura.info 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, photoventura.info 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, photoventura.info and any third-party services may collect files that record interaction with photoventura.info (System logs) or use other Personal Data (such as the IP Address) for this purpose.
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 photoventura.info 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 photoventura.info (or third-party services employed in photoventura.info), which can include: the IP addresses or domain names of the computers utilized by the Users who use photoventura.info, 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 photoventura.info 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 photoventura.info. The Data Controller, unless otherwise specified, is the Owner of photoventura.info.
photoventura.info (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by photoventura.info 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 privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to photoventura.info, if not stated otherwise within this document.