Privacy Policy of Caress Flow srl

This Website collects some Personal Data from its Users.



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Owner and Data Controller

CARESS FLOW srl
Via dei Giudei 39
Funo di Argelato 40050 (BO)
Italy

P.I.: 03729591200

Owner contact email: info@caressflow.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address; Tracker; first name; last name; phone number; Usage Data; geographic position; city; various types of Data.

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 Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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 Website.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational 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 Website (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

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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: User database management, Advertising, Remarketing and behavioural targeting, Location-based interactions, Analytics, Heat mapping and session recording, Managing data collection and online surveys, Contacting the User, Handling payments, Platform services and hosting and Marketing.

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:

  • Advertising

    This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    Direct Email Marketing (DEM) (this Website)

    This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.

    Personal Data processed: email address; first name; last name.

    Direct marketing via SMS (this Website)

    This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.

    Personal Data processed: first name; last name; phone number.

    Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

    Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt out.

    Google Ads conversion tracking (Google Ireland Limited)

    Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

    Facebook Lookalike Audience (Meta Platforms Ireland Limited)

    Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services.
    On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience.

    Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

  • Analytics

    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

    Google Analytics (Universal Analytics) (Google Ireland Limited)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

  • Contacting the User

    Phone contact (this Website)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.

    Personal Data processed: phone number.

    Contact form (this Website)

    By filling in the contact form with their Data, the User authorises this Website 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; email address; first name; last name; phone number; various types of Data.

  • Handling payments

    Unless otherwise specified, this Website 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 Website 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.

    PayPal (PayPal Inc.)

    PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

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

    Place of processing: See the PayPal privacy policy – Privacy Policy.

  • Heat mapping and session recording

    Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
    Some of these services may record sessions and make them available for later visual playback.

    Hotjar Heat Maps & Recordings (Hotjar Ltd.)

    Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
    Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

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

    Place of processing: Malta – Privacy Policy – Opt Out.

  • Location-based interactions

    Non-continuous geolocation (this Website)

    This Website 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 authorisation has been provided, the User’s location data may be tracked by this Website.
    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: geographic position.

  • Managing data collection and online surveys

    This type of service allows this Website 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.

    Facebook lead ads (Meta Platforms Ireland Limited)

    Facebook lead ads is an advertising and data collection service provided by Meta Platforms Ireland Limited that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.

    Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.

    Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.

    Personal Data processed: city; email address; first name; last name; phone number.

    Place of processing: Ireland – Privacy Policy – Opt out.

  • Marketing

    HighLevel, Inc.

    Privacy Policy
    Last Updated SEPTEMBER 2023

    1. Overview

    HighLevel Inc. (“HighLevel,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we collect and use your Personal Information when you visit our website at https://www.gohighlevel.com or otherwise use the Platform as described further in the Terms of Service, and that you may provide in electronic messages to HighLevel.

    Please read this Privacy Policy to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing or using the Platform, you agree and consent to this Privacy Policy.

    HighLevel may change this Privacy Policy at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

    This Privacy Policy is subject to and governed by the HighLevel Terms of Service. The Services are part of the Platform and are described further in the Terms of Service.

    2. The Types of Information That HighLevel Collects About You and How HighLevel Collects Information About You

    HighLevel may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

    “Personal Information” refers to data by which you may be personally identified, such as name, email address, employer, job title and department, and telephone number.

    “Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

    We collect Information:

    Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase or request information from HighLevel, we will ask for things like your name, contact, billing, shipping and communication information, and account ID or credentials in order to fulfill your request. If you set up an appointment with us through the Platform, attend a trade show or event, or otherwise contact us, you may also voluntarily provide similar information. If you submit any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by You asking for their consent).

    From third parties. We obtain information through partners, vendors, suppliers and other third parties. The parties from whom we obtain information are typically corporate enterprises (although some may also be educational or public enterprises) and they may be located in any of the locations in which we do business. These enterprises largely fall into the following categories: Advertising and marketing companies, data set and information vendors, public database providers, social media platforms, partners, providers of products or services, hosts or vendors at events or trade shows, research partners, or enterprises that use HighLevel Services. We take steps to confirm that information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us. We might also obtain information through a partner, or co-create datasets with a partner, as part of our business operations. This kind of data is used for work like improving the Platform and other HighLevel Services, enhancing existing products and developing new capabilities and features. In some cases we combine Personal Information about individuals that we receive from multiple sources, including directly collected from you or through your use of the Platform.

    Automatically as you navigate through the Platform or during the time in which you utilize our Services. We collect information about how you interact with the Platform through the use of cookies, pixel tags, and similar technologies. Please view our separate Cookies Policy for more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.

    3. How HighLevel Uses Personal Information It Collects About You and the Purposes for the Collection and Use

    We use Personal Information that we collect about you or that you provide to us for the following purposes:

    For Functionality and Development of the Platform and HighLevel Services. We use information to provide, offer, and personalize the Platform and other HighLevel Services provided to you. Some information, like your IP address, is used to communicate with your device to provide network connectivity, measure usage levels of the Platform, diagnose server problems and provide security features. Other business purposes that depend on use of your information include data analysis related to testing, modifying, improving or developing new products, services and technologies, and to identify trends. We use cookies to make our websites and the Platform operate, work more efficiently, and provide analytic information. Technologies similar to cookies, such as pixel tags are also used in connection with the Platform. For more information on our use of cookies, please read our Cookies Policy.

    For Customer Support, Platform Updating and Reporting. The Platform may use information to provide HighLevel with updates and reports, and to check that the Platform is working properly. Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernized, in order to provide you with the up-to-date security, versions, features, options and controls associated with your systems or devices. We rely on information to analyze performance and improve and maintain the Platform. We also rely on Personal Information you provide to us to provide you with customer support for the Platform and other HighLevel Services, and to verify eligibility for promotional offers.

    For Business Operations. We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities. Other business purposes that depend on use of your Personal Information include crime or fraud monitoring and prevention, protecting our legal rights, and performing contractual obligations. We also use Personal Information to contact you to advertise, market and sell HighLevel Services in accordance with your communications preferences.

    To Communicate. We use contact information to send messages; to provide HighLevel Services; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences. We occasionally conduct surveys, or do focused research or studies which may require you to voluntarily share Personal Information in order to participate. These activities typically have additional notices that provide more information about the use of your Personal Information and to which you may be asked to consent.

    For Advertising and Marketing. We may use Personal Information collected from you, combined with information about what advertisements you viewed and other information we collect, to enable us to provide personalized content and to study the effectiveness of advertising and marketing campaigns. You may choose whether to allow or deny uses or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, we may not be able to provide you with certain personalized HighLevel Services and content on the Platform.

    For Statistical Purposes to Improve the Platform. We may compile Platform statistics into traffic reports, which help HighLevel understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the HighLevel Platform, we are likely to highlight that information on the Platform home page. This Information helps us create a better overall experience for Platform users.

    LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): If you are in the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

    However, we will collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

    If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.

    Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.

    HighLevel is the Data Controller of all Personal Information collected through the Platform in the EEA and the United Kingdom, except with respect to the Services (where HighLevel is the Data Processor) or where a supplemental Privacy Policy says otherwise. The contact details for HighLevel are set out in the "HOW TO CONTACT US” section.

    If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “HOW TO CONTACT US” Section below.

    RETENTION OF YOUR PERSONAL INFORMATION: We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further information. And in some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    4. How HighLevel Protects Your Information

    The Platform is designed to provide reasonable and appropriate administrative, technical and organizational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. We require our suppliers and vendors to apply similar protections when they access or use Personal Information that we share with them. Users of the Platform must also do their part in protecting the data, systems, networks, and service they are utilizing. No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any HighLevel account has been compromised), please immediately notify us by contacting us using the instructions in the “HOW TO CONTACT US” section below.

    5. When HighLevel Shares Your Information

    We work through our affiliates to provide the Platform and other HighLevel Services. We also work with authorized suppliers and business partners. When we share your Personal Information with these companies, we put in place appropriate measures to limit the use of your information only for legal and authorized purposes that are consistent with this Privacy Policy, as well as appropriate confidentiality and security measures.

    We also share information with third parties for advertising and marketing; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Platform; and to protect our legal rights. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

    With Affiliates and Subsidiaries. For purposes limited to and consistent with this Privacy Policy.

    With Suppliers. Our authorized vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at HighLevel, and we process Personal Information using these tools as a regular course of business. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.

    With Partners. We occasionally have relationships with third parties that are not suppliers or vendors but are working with us to offer certain opportunities such as marketing and similar promotions, to enable joint products or research studies, or to facilitate services on the Platform. In these cases, additional terms or Privacy Policies may be provided. For third parties or uses not described in this Privacy Policy, we share your information only with a lawful basis to do so.

    For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns.


    In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform or other HighLevel Services, and other websites. Content may be based on information obtained, for example, through prior purchases or transactions, through your device’s physical location, through information about what advertisements and content you have viewed, or through cookies and similar technologies relating to your access to and use of the Platform and other websites. Please read our Cookies Policy for more information. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable Platform Services and content.

    Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

    With Your Consent. HighLevel may disclose your Personal Information to any other person or entity where you consent to the disclosure. For information about how to decline our advertising and marketing, please see the section entitled "Your Choices & Rights" below.

    We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new HighLevel Services.

    HighLevel does not sell any of your Personal Information for monetary compensation.

    6. Information From Children

    We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we have collected the Personal Information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any Information about yourself to HighLevel, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please use one of the methods provided under the “HOW TO CONTACT US” section below.

    7. Links to Other Websites and Services

    We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on HighLevel’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to other organizations through or in connection with the Platform or other HighLevel Services.

    8. Do Not Track

    Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

    9. YOUR LEGAL RIGHTS

    HighLevel respects your rights in how your Personal Information is used and shared. Depending on where you live, you may have rights to request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from HighLevel at all). See below for more information, depending on your location.

    10. European Privacy Rights

    If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additional choices and rights may be available to you depending on which HighLevel Services you use.

    Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “HOW TO CONTACT US” section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.


    At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below. We may charge a processing fee for this service where permitted by law and we will require evidence of your identity before fulfilling your request.

    Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland. You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. You can exercise these rights by making a written request in one of the ways described in the “HOW TO CONTACT US” section below.

    Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.

    If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration.

    Advertising and Marketing Choices. We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy includes more information on HighLevel’s use of such technologies for advertising and other purposes.

    11. International Compliance

    HighLevel is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third party service providers, who may be located in a different country to you.

    HighLevel transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

    Whenever HighLevel transfers Personal Information beyond the country of origin, we will do so in accordance with applicable laws. For Personal Information originating in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland that is transferred to a HighLevel entity outside the EEA, UK, or Switzerland, HighLevel participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). HighLevel commits to the DPF Principles and, as needed, will take additional steps to provide appropriate safeguards for the Personal Information we transfer. The Federal Trade Commission has jurisdiction over HighLevel’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF). HighLevel may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. HighLevel is liable in cases of onward transfers to third parties.

    12. Data Privacy Framework

    HighLevel Inc. and LeadConnector LLC comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. HighLevel has certified to the U.S. Department of Commerce that HighLevel and LeadConnector adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. HighLevel has certified to the U.S. Department of Commerce that HighLevel and Leadconnector adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

    13. California Privacy Rights

    This section is addressed to California residents only and provides more information about your rights under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), as amended. Subject to certain exceptions, the CCPA grants to California residents the rights to: be notified about the collection, use, disclosure, sale or sharing of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the “sale” or “sharing” of Personal Information (where such information is sold or shared); limit the use or disclosure of Sensitive Personal Information (as defined under CCPA); and to not be discriminated against for exercising such rights.

    HighLevel does not sell your Personal Information. If you wish to exercise your right to opt-out of HighLevel using your Personal Information for cross-contextual targeted advertising purposes (called “sharing” under the CCPA), you may do so by using the details in the “HOW TO CONTACT US” section or the appropriate withdrawal mechanism provided to you on the Platform.

    You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that HighLevel may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CCPA. If you submit a request to exercise rights under CCPA, HighLevel will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with HighLevel and the sensitivity of Personal Information at issue. If HighLevel denies your request, we will explain why.

    You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, HighLevel may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and HighLevel will respond to any request from such authorized agent in accordance with the CCPA.

    The Privacy Policy describes the categories of Personal Information that HighLevel collects and how HighLevel uses such Personal Information. If HighLevel collects Sensitive Personal Information, we limit our use of the Sensitive Personal Information to uses: (1) you have authorized, (2) that are required to fulfill your requests for goods or services, or (3) that are otherwise allowed by the CCPA or required by other laws or regulations.

    The categories of Personal Information collected, disclosed, and sold from California residents over the preceding 12 months and HighLevel’s applicable retention periods include:

    Personal Information Category Retention Period Business Purpose Collected Disclosed Sold
    Identifiers (such name, address, IP address, email, etc.)

    See Section 3 of Privacy Policy: “Retention of Your Personal Information”

    For functionality, customer support, business operations, communication, advertising and marketing, and statistical purposes.

    Yes

    Yes

    No

    Personal information defined in Civil Code Section 1798.80(e) (such as signature, SSN, financial information, and insurance information, etc.)

    No

    No

    No

    Protected personal information (such as gender, religion, sexual orientation, or disability)

    No

    No

    No

    Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)

    See Section 3 of Privacy Policy: “Retention of Your Personal Information”

    For development, customer support, business operations, communication, advertising and marketing, and statistical purposes.

    Yes

    No

    No

    Biometric information

    No

    No

    No

    Internet or other similar network activity (such as information on a consumer’s interaction with a website, application, or advertisement, etc.)

    See Section 3 of Privacy Policy: “Retention of Your Personal Information”

    For functionality, business operations, and statistical purposes.

    Yes

    Yes

    No

    Geolocation data

    No

    No

    No

    Audio, electronic, visual, thermal, or olfactory information

    No

    No

    No

    Professional or employment-related information

    No

    No

    No

    Education information

    No

    No

    No

    Inferences (such as analytics and preferences

    Yes

    Yes

    No

    14. Colorado Privacy Rights

    This section is addressed to Colorado residents only and provides more information about your rights under the Colorado Privacy Act or “CPA.” Subject to certain exceptions, the CPA grants to Colorado residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; and request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling.

    You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that HighLevel may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by CPA. If you submit a request to exercise rights under CPA, HighLevel will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with HighLevel and the sensitivity of Personal Information at issue. If HighLevel denies your request, we will explain why. If we have not responded to your request or asked for additional time to respond to your request within 45 days after you send us a request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US” section.

    You can designate an authorized agent to make a request under the CPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, HighLevel may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CPA.

    15. Connecticut Privacy Rights

    This section is addressed to Connecticut residents only and provides more information about your rights under the Connecticut Data Privacy Act or “CTDPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action by contacting us using the details in the “HOW TO CONTACT US” section.

    16. Utah Privacy Rights

    This section is addressed to Utah residents only and provides more information about your rights under the Utah Consumer Privacy Act or “UCPA.” You can exercise your rights by using the details in the “HOW TO CONTACT US” section.

    17. Virginia Privacy Rights

    This section is addressed to Virginia residents only and provides more information about your rights under Virginia’s Consumer Data Protection Act or “VCDPA.” Subject to certain exceptions, the VCDPA grants to Virginia residents the rights to: be notified about the collection, use, disclosure, or sale of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the use of Personal Information for targeted advertising, sale, or certain profiling; and to not be discriminated against for exercising such rights.

    You can request access to, correction of or deletion of your Personal Information by using the details in the “HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note that HighLevel may still need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting such deletion, to comply with applicable law, or for other purposes permitted by VCDPA. If you submit a request to exercise rights under VCDPA, HighLevel will ask you to provide certain information to verify your identity. This information will depend on your prior interactions with HighLevel and the sensitivity of Personal Information at issue. If HighLevel denies your request, we will explain why. If we inform you that we decline to take action regarding your request, you have the right to appeal our failure to take action. To appeal our failure to take action, contact us using the details in the “HOW TO CONTACT US'' section.

    18. How To Contact Us About This Privacy Policy

    To ask questions about this Privacy Policy and our privacy practices, contact us at legal@gohighlevel.com or by mail at:

    HighLevel Inc.

    ATTN: Legal Department400 North Saint Paul St., Suite 920

    Dallas, Texas 75201

    For the UK:

    Rickert Services Ltd U

    - HighLevel Inc. -

    PO Box 1487

    Peterborough

    PE1 9XX United

    Kingdomart-27-rep-highlevel@rickert-services.uk

    For the EU:

    Rickert Rechtsanwaltsgesellschaft mbH

    - HighLevel, Inc. -

    Colmantstraße

    1553115 Bonn

    Germany

    art-27-rep-highlevel@rickert.law

    In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, HighLevel commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact HighLevel at: legal@gohighlevel.com

  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website 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.

    WordPress.com (Automattic Inc.)

    WordPress.com is a platform provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows the Owner to build, run and host this Website.

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

    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  • Remarketing and behavioural targeting

    This type of service allows this Website and its partners to inform, optimise and serve advertising based on past use of this Website by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
    Some services offer a remarketing option based on email address lists.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    Facebook Remarketing (Meta Platforms Ireland Limited)

    Facebook Remarketing is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Website with the Facebook advertising network.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Facebook Custom Audience (Meta Platforms Ireland Limited)

    Facebook Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Website with the Facebook advertising network.

    Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: email address; Tracker.

    Place of processing: Ireland – Privacy Policy – Opt Out.

    Google Ads Remarketing (Google Ireland Limited)

    Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

    In order to understand Google's use of Data, consult Google's partner policy.

    Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Ireland – Privacy Policy – Opt Out.

  • User database management

    This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

    ActiveCampaign (ActiveCampaign, Inc.)

    ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

    Personal Data processed: email address; Tracker; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy Policy.

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.

Cookie Policy

This Website uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

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

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 of Data transfers to a country outside the European Union or to any international organisation 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.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

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.

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 Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (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 Website 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)

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.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised 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 Website 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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

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 policy relates solely to this Website, if not stated otherwise within this document.

Latest update: 8 March 2024

This document has been created with the iubenda Privacy and Cookie Policy Generator. See also the Terms and Conditions Generator. iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

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