Owner and Data Controller
Formap di Fabrizio Parzanese, Via Leonilde Jotti 4, Pianezza, 10044, Italia.
Owner contact email: info@exphire.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Trackers; Usage Data; number of Users; city; device information; session statistics; latitude (of city); longitude (of city); browser information; email address; first name; last name; date of birth; country; gender; company name; Data communicated while using the service; Calendar permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Phone permission; Bluetooth sharing permission; Social media accounts permission; Biometric Data access permission; Call permission; User ID; username; Data communicated in order to use the Service; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); phone number; physical address; password; geographic position; VAT Number; profession; profile picture; screenshots; workplace; state; county; ZIP/Postal code; various types of Data; Tax ID; field of activity; number of employees; website; session duration; scroll-to-page interactions; clicks; time zone; mouse movements; interaction events; diagnostic events; page events; custom events; layout details; positional information; Universally unique identifier (UUID); answers to questions; keypress events; motion sensor events; scroll position; touch events; billing address; payment info.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Advertising, Remarketing and behavioral targeting, Displaying content from external platforms, Interaction with external social networks and platforms, Managing data collection and online surveys, Device permissions for Personal Data access, Handling activities related to productivity, Hosting and backend infrastructure, Backup saving and management, Collection of privacy-related preferences, Contacting the User, Content performance and features testing (A/B testing), Data transfer outside the EU, Tag Management, Traffic optimization and distribution, User database management, Heat mapping and session recording, Managing contacts and sending messages, Interaction with data collection platforms and other third parties, SPAM protection, Platform services and hosting, Human resources and Selling goods and services online.
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”.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.
Biometric Data access permission
Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.
Bluetooth sharing permission
Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Call permission
Used for accessing a host of typical features associated with telephony.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
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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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, 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 for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. 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.
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 Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Google Ads Similar audiences (Google Ireland Limited)
Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
LinkedIn Ads (LinkedIn Ireland Unlimited Company)
LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Application.
Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; 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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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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 Application. 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.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Facebook Lookalike Audience (Meta Platforms Ireland Limited)
Facebook Lookalike Audience is an advertising and behavioral 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 behavior to Users who are already in a Custom Audience list on the base of their past use of this Application or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
ShareThis (Sharethis Inc.)
ShareThis is an advertising and behavioral targeting service provided by Sharethis Inc. that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application. Users can opt out of ShareThis's use of Trackers for ads personalization by visiting this opt-out page.
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:
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a sale according to the CCPA and VCDPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA
Meta Audience Network (Meta Platforms Ireland Limited)
Meta Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Facebook's use of Data, consult Facebook's data policy.
This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
AddThis (Oracle Corporation)
AddThis is an advertising and behavioral targeting service provided by Oracle Corporation that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application and connects the activity of this Application with the Oracle advertising network. Users can opt out of Oracle's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Trackers; Universally unique identifier (UUID); Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt out.
Legal basis for data transfer: No data transfer.
Data retention period: Keeping the Data until consent is withdrawn.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA and VCDPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA
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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 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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.
Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
YouTube Analytics and Reporting API (Google Ireland Limited)
YouTube Analytics and Reporting API is a video content analytics service provided by Google Ireland Limited.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated while using the service; device information; Trackers; Usage Data; User ID; username.
Place of processing: Ireland – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Analytics Advertising Reporting Features (Google Ireland Limited)
Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Backup saving and management
This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
OVH Storage and backup (OVH Srl)
OVH Storage and backup is a service to save and manage backups provided by OVH Srl.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
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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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Backup on Google Drive (Google Ireland Limited)
Google Drive is a service to save and manage backups provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: Ireland – Privacy Policy.
Legal basis for data transfer: No data transfer.
Data retention period: Keeping the Data until consent is withdrawn.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Collection of privacy-related preferences
This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Cookie Solution (iubenda srl)
The iubenda 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 this Application.
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:
-
a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
iubenda Consent Solution (iubenda srl)
The iubenda Consent Solution 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:
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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application 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; company name; country; county; date of birth; email address; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; Tax ID; Trackers; Usage Data; User ID; various types of Data; VAT Number; website; ZIP/Postal code.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet or other electronic network activity information; employment related information; inferences drawn from other personal information.
This processing constitutes:
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a sale according to the VCDPA
Mailing list or newsletter (this Application)
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 this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; state; Trackers; Usage Data; website; ZIP/Postal code.
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data until consent is withdrawn.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet or other electronic network activity information; employment related information.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
Phone contact (this Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Optimize 360 (Google Ireland Limited)
Google Optimize 360 is an A/B testing service provided by Google Ireland Limited ("Google").
This service allows the Owner to target groups of Users on the base of their past use of this Application. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Bluetooth sharing permission; Calendar permission; Call permission; Phone permission; Social media accounts permission.
Category of personal information collected according to the CCPA: biometric information; internet or other electronic network activity information; geolocation data.
This processing constitutes:
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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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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 this Application 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 Programmable Search Engine with AdSense (Google Ireland Limited)
Google Programmable Search Engine is a search engine embedding service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Google Programmable Search Engine may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Calendar widget (Google Ireland Limited)
Google Calendar widget is a calendar content visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
YouTube IFrame Player (Google Ireland Limited)
YouTube IFrame Player is a video content visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Trackers; Usage Data; User ID; username.
Place of processing: Ireland – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
YouTube video widget (Google Ireland Limited)
YouTube is a video content visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Trafft widget
Trafft widget is a calendar content visualization service provided by TOUCH ME SOFT d.o.o that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: calendar information; device information; email address; geographic position; name; phone number; Trackers.
Place of processing: Republic of Serbia – Privacy Policy: https://trafft.com/privacy-policy/
Legal basis for processing: Legitimate interest.
Legal basis for data transfer: No data transfer.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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Handling activities related to productivity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Google Workspace (Google Ireland Limited)
Google Workspace is an integrated suite of cloud-based productivity, collaboration and storage services provided by Google Ireland Limited. Gmail or other G Suite services are not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside these services for advertising purposes in any other way.
Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; screenshots; Trackers; Usage Data; username; VAT Number; workplace.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, thermal, olfactory, or similar information; employment related information.
This processing constitutes:
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a sale according to the CCPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Heat mapping and session recording
Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
OVHcloud (OVH Srl)
OVHcloud is a hosting and backend service provided by OVH Srl.
Personal Data processed: Usage Data.
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:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Human resources
Manatal
Manatal.CO.Ltd is an AI Recruitment Software enabling human resources departments and recruitment agencies to source and hire in the most effective way.
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; physical address; profession; purchase history; Trackers; Usage Data; username; CVs; various types of Data as specified in the privacy policy of the service.
Place of processing: Thailand – https://www.manatal.com/privacy-policy
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: 2 years.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
HiPeople
HiPeople is a User assessment and reference check platform service provided by HiPeople GmbH.
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; social profile url, physical address; profession; purchase history; Trackers; Usage Data; username; assessments scores; previous employer and colleagues data; various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – https://www.hipeople.io/privacy
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: 6 months.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Coderbyte
Coderbyte is a User assessment and technical candidates screening platform service provided by Coderbyte Enterprise Inc.
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; social profile url, physical address; profession; purchase history; Trackers; Usage Data; username; assessments scores; various types of Data as specified in the privacy policy of the service.
Place of processing: USA – https://coderbyte.com/privacy
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: 3 months.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Testlify
Testlify is a User assessment and technical candidates screening platform service provided by Testlify, Inc. 2823 Oakley Ave, Bensalem PA 19020, United States
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; social profile url, physical address; profession; purchase history; Trackers; Usage Data; username; assessments scores; interview and candidates' screening answers, various types of Data as specified in the privacy policy of the service.
Place of processing: USA – https://testlify.com/privacy-policy/
Terms and conditions: https://testlify.com/terms/
Legal basis for processing: Consent.
Legal basis for data transfer: Country providing an adequate level of protection.
Data retention period: 2 years.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
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 this Application 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.
WP Forms
The Wp Forms widget is a service for interacting with the WP Forms data collection platform provided by WPFORMS LLC
Personal Data processed: billing address; city; company name; country; county; Data communicated while using the service; date of birth; email address; field of activity; first name; gender; language; last name; number of employees; phone number; physical address; picture; profession; profile picture; Tax ID; Trackers; Usage Data; User ID; username; various types of Data as specified in the privacy policy of the service; VAT Number; website; workplace.
Place of processing: United States – Privacy Policy: https://wpforms.com/privacy-policy/
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data until consent is withdrawn.
This processing constitutes:
-
a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
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 this Application.
The interaction and information obtained through this Application 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 this Application isn’t being connected back to the User’s profile.
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
AddToAny (AddToAny LLC)
AddToAny is a service provided by AddToAny LLC, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Data collected through the service may be used to help deliver interest-based advertising. Users can opt out of third-party interest-based advertising by visiting the Network Advertising Initiative opt-out page.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
YouTube button and social widgets (Google Ireland Limited)
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
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.
Suitedash Email
Suitedash is a User database management service provided by Suitedash, Inc.
Personal Data processed: email address; Usage Data.
Place of processing: Canada – https://suitedash.com/privacy-policy/
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data until consent is withdrawn.
This processing constitutes:
-
a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
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; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; last name.
Place of processing: Ireland – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application.
Personal Data processed: billing address; Data communicated while using the service; device information; email address; first name; last name; payment info; phone number; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Legitimate interest.
Place of processing: United States – Privacy Policy.
Legal basis for data transfer: No data transfer.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application 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 behavioral 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.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application 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 personalization by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Facebook Custom Audience (Meta Platforms Ireland Limited)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Facebook Remarketing (Meta Platforms Ireland Limited)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Remarketing with Google Analytics (Google Ireland Limited)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Google Signals (Google Ireland Limited)
This Application uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Application with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Selling goods and services online
This type of service helps the Owner to sell goods, provide services or monetize online content. To this end, the services listed below may for instance allow the Owner to process payments, set up subscription models, track orders, and manage deliveries.
Zenlead Inc
Apollo.io is a User database management, lead collection database and direct marketing service provided by Zenlead, Inc.
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; physical address; profession; purchase history; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: USA – https://www.apollo.io/company/privacy-center/
If you want to exclude your personal data from their database and avoid to be contacted by us, please use this link to remove all your personal data https://www.apollo.io/privacy-policy/remove/
Legal basis for processing: Legitimate interest.
Legal basis for data transfer: Country providing an adequate level of protection.
Data retention period: 2 years.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
SPAM protection
This type of service analyzes the traffic of this Application, 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 Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Legal basis for processing: Legitimate interest.
Place of processing: Ireland – Privacy Policy.
Legal basis for data transfer: No data transfer.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
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:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application 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 Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Traffic optimization and distribution
This type of service allows this Application 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 this Application 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.
jsDelivr (Prospect One Sp. z o.o. sp. k.)
jsDelivr is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.
Personal Data processed: Usage Data.
Place of processing: Poland – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
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 Application, 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 Application.
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 Application.
Suitedash CRM
Suitedash is a User database management service provided by Suitedash, Inc.
Personal Data processed: company name; country; Current City; email address; first name; gender; last name; phone number; physical address; profession; purchase history; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: Canada – https://suitedash.com/privacy-policy/
Legal basis for processing: Consent.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data until consent is withdrawn.
This processing constitutes:
-
a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
-
Disclosure for Candidates, Clients, Suppliers, and Experts Contributors
We want to provide a secure and reliable user experience. We ensure that the information you send to us, or that we collect, through various channels (including through our website, through written correspondence (including e-mail), through conversations or meetings with our consultants, or through any of our global locations or websites), is used only for the purposes set out in this Privacy Notice.
Through this Privacy Notice, we aim to inform you about the types of personal data we collect, the purposes for which we use the data, and how the data is processed. We also aim to fulfill the transparency obligation under the EU General Data Protection Regulation 2016/679 ("GDPR") and any applicable national laws.
Purpose
The protection of your personal data is our priority. This Privacy Policy explains how our Company processes and protects personal data for:
- candidates who register with us for roles we are managing for other employers and for roles at our Company, or through our website, job boards, social media sites or other sources;
- potential candidates
- potential clients;
- existing clients;
- potential expert contributors;
- experienced existing employees;
- business contacts at our customers and suppliers; and
- users of our websites;
(collectively, "you" or "your").
It also informs you of your privacy rights, including the right to object to our processing. If you would like to contact us, please see the "How to Contact Us" section of this policy.
Personal data we collect
Candidates
When you register with us as a candidate to provide job search services, we process your personal data, including, but not limited to, your name, contact information, and CV information. Where permitted by law, we may also collect information about your health (e.g., disability, for the purpose of appropriate employment treatment), diversity reasons, including race, ethnic origin, sexual orientation, and religion (for equal opportunity monitoring), as well as references of any outstanding criminal convictions, if requested by a client or by us, if you are applying for a role with us. In this case, Formap di Fabrizio Parzanese acts as the Data Controller of your data and manages the procedure for which you have applied.
If you use our website, click links in emails we send you, open or forward them, or sign up to receive job alerts or other content from us, we also collect personal data from those interactions.
We also obtain personal data about you from third parties, including,
- references - when you are offered a job or there is an intention to proceed with a job;
- previous employers - to confirm dates of employment;
- educational institutions - to verify your academic qualifications;
- credit reference agencies-if we need to verify your financial situation;
- publicly available sources such as LinkedIn and social media sites to refine the information we have about you to help us find roles best suited to you;
- clients to whom we have provided your CV and who have engaged with you on a job application or provided feedback on your CV.
- experienced staff, technical and behavioral experts who provide feedback of various kinds on your profile and CV.
Potential Candidates
We collect personal data about you, including your name, contact information, and professional biographical details obtained from publicly available sources such as LinkedIn, CV websites, and social media websites, so that we can contact you if we think you may be interested in our job search services in the future. We may also obtain your personal information from other candidates or employers who recommend you as a contact. In this case, the Data Controller of your data will be Formap di Fabrizio Parzanese who identified you as a potential client.
Potential Clients
We collect your contact information as well as data related to your function or position to establish business relationships with your company. In this case, the Data Controller of your data will be Formap di Fabrizio Parzanese who via identified you as a potential customer.
Users of our website or apps.
We collect personal data such as your IP address and other data about your device that we need to provide you with our online content. We also collect data about your interactions with our website or apps, such as pages viewed. If you contact us, we will also collect information about your request. We use cookies and similar technologies to collect much of this information, and our cookie policy (https://exphire.com/cookie-policy/) provides further details on the point. In this case, the Data Controller of your information will be Formap di Fabrizio Parzanese to which the website belongs, whose contact details are provided on the website and in this Privacy Policy.
Clients
We collect personal data such as your name, job title and contact information. We also process personal data related to the contact we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent you. We also process feedback you provide to us about our candidates or those you have identified and decide to submit to our scrutiny and/or that of our assigned staff (such as Technical and Behavioral Experts), and if you provide us with information about candidates (e.g., if you confirm that a candidate has worked with you or provide us with a reference), we will obtain your data from the candidate and keep a record of the personal data you have provided to us about that candidate. In the event that your candidates do not consent to a transfer of personal data to a third party, we ask you to invite candidates to express direct consent to their data processing via a specially-prepared online form.
We process personal data about you from public domain sources such as LinkedIn and social networking sites, or because you were a delegate at one of our events or an event where the organizer was authorized to share delegate details with us.
Suppliers and Partners
We typically collect your name and contact details as a business contact for your organization and/or from public domain sources such as LinkedIn and social networking sites.
Contributing Experts
Technical and Behavioral Experts collaborate with ExpHire and clients in recruitment processes. We collect data about your interactions with our website or apps, such as page views. If you contact us, we will also collect information about your inquiry. We use cookies and similar technologies to collect much of this information, and our cookie policy (https://exphire.com/cookie-policy/) provides more details on the point. We collect personal data such as your name, job title and contact information. We also process personal data about the contact we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent you. We also process feedback you give us about candidates and clients. We enter into specific collaboration agreements with Experts that guarantee the privacy of clients and candidates and prevent Experts from making copies of personal data of candidates and clients that they gain access to during their collaboration. We similarly guarantee the Experts and their exposed personal data exclusively to Clients.
Provision of your personal data
In some cases, it will be necessary for you to provide us with personal data. If you do not provide us with the requested personal data, we may not be able to provide you with our services.
How we use your personal data
Candidates
We use your personal data to:
- provide you with job search services;
- communicate with you;
- allow you to upload your CV and apply for positions;
- personalize your experience by creating a candidate profile;
- enable us to monitor equality and diversity;
- allow us to assess your technical skills and behavioral aptitudes through the use of Expert contributors to our company with whom we share your personal data such as your name, contact information, Resumes, other writings and processed by you produced ;
- share your personal data with our client companies where there is a match of your profile to the recruitment needs of the clients ;
- provide you with advice on interviews and salaries ; and
- send you direct marketing to inform you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices.
- We also use targeted and relevant banner ads on our website and within your social networks to present you and people like you with jobs and content that we believe may be of interest to you. We target such ads based on your previous interactions with our website, emails, and through your agreements with our employees and contractors.
Your interaction with our ads may be used to measure the effectiveness of our advertising campaigns and to improve our marketing strategy. This processing is done through cookies and on the condition that you have previously provided consent.
Potential Candidates and Clients
We use your personal data to:
- determine your possible interest in our services and how we can assist you;
- contact you and find out if you are interested in our services.
Users of our website or apps.
We may use your personal data to:
- improve and personalize your experience when you use our website or apps; and
- personalize the advertising you receive from us.
Clients
We may use your personal data:
- To provide recruitment services to you;
- To communicate with you;
- to obtain feedback from you about our services through customer satisfaction surveys in order to improve our services and develop new ones;
- To maintain our business relationship with you;
- To answer your questions when you contact us;
- for the performance of contractual obligations to you;
- for the establishment, exercise or defense of legal claims; and
- for direct marketing purposes.
Providers
We use your personal data:
- To communicate with you;
- To maintain our business relationship with you;
- To answer your questions when you contact us;
- for the performance of contractual obligations to you;
- for the establishment, exercise or defense of legal claims; and
- for direct marketing purposes.
Expert Contributors
We may use your personal data:
- to inform you of possible recruitment projects;
- To enable you to upload your CV and become our collaborators;
- to communicate with you;
- to obtain feedback from you about our services through satisfaction surveys in order to improve our services and develop new ones;
- To maintain our business relationship with you;
- To answer your questions when you contact us;
- for the performance of contractual obligations to you;
- for the establishment, exercise or defense of legal claims; and
- for direct marketing purposes.
All users of our service can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in the communications we send you or by contacting us.
Legal Basis for the Processing of Your Personal Data
Under the GDPR, the processing of your personal data is based on the following legal bases:
(a) Performance of a contract - to fulfill our obligations under a contract with you, such as when clients contract for services and candidates agree to our terms and conditions. Or to prospective clients or candidates to take the steps that would be required to enter into a contract with us.
(b) Fulfillment of a legal obligation - when it is necessary for us to process your personal data to fulfill legal or secondary source obligations.
(c) Our or third parties' legitimate interests - including:
- responding to your inquiries and requests (the Companies' legitimate interest in such a case is to maintain constant and up-to-date communication with customers and applicants as part of any business relationship);
- Optimizing the performance of our website and user experience;
- contact potential clients in order to establish business relationships with clients (the legitimate interest of Formap di Fabrizio Parzanese is to maintain relationships of any kind with the company where the contact person works).
- To inform you about our services, job opportunities, industry reports and insights, events, promotions and contests (the legitimate interest of Formap di Fabrizio Parzanese is to inform customers, experienced employees and candidates about similar services and products) and;
- ensure that our operations are conducted efficiently or provide surveys on the satisfaction with our services;
- perform actions necessary for the assessment of candidates and more generally for recruitment projects for which we are in charge (for example: sharing and analyzing CVs, evaluating tests, arranging interviews and related feedback).
We have conducted a legitimate interest assessment to make sure that our interests are not subordinated to your interests or fundamental rights and freedoms. You can request such an assessment from the contact details below.
(d) Consent In some circumstances, we will ask for your consent to process your personal data. For example, if you register for a role, we will offer you the opportunity to register for similar job postings. To the extent that we are processing your personal data based on your consent, you have the right to revoke it at any time. Please contact us if you wish to revoke your consent.
With whom we share your personal data
Under certain circumstances we will share your personal data with:
- Other companies in our Group
- Third parties
If you are a candidate, we share your personal data with clients at which positions of interest to you are available and with Collaborating Experts. The applicable legal basis in this case would be the same as described above; the execution of the contract with the client or candidate or taking the necessary steps to conclude a contract and the legitimate interests of Formap di Fabrizio Parzanese in providing candidate information and services to clients.
We also share your personal data and, where necessary and permitted by law, special category data with third-party service providers who perform services and functions on our behalf, such as:
- employment reference checks;
- expert collaborators who conduct an assessment on the technical skills and behavioral aptitudes of candidates;
- qualification checks;
- criminal background checks (if required);
- checks on details you provide from third-party sources;
- psychometric evaluations or ability tests;
- hosting of personal data for us;
- professional counseling;
- data analysis;
- testing and development work on our business technology systems;
- administration of surveys or contests on our behalf;
- support in communicating with you; and
- research and mailing house or other direct marketing services.
We contractually require minimum standards of confidentiality and data protection from our third-party service providers. If we need to send personal data outside the EEA, we will ensure that appropriate safeguards are in place, such as Model Clauses.
Other Disclosures
In addition, we may disclose your personal data:
- If we are legally required to do so;
- To law enforcement, regulatory authorities or other government officials; and
- to new business owners and their advisors in the event of a reorganization, merger, sale, joint venture, divestiture or other transfer or disposition of all or part of our business.
Security of your personal information
We have taken and maintain appropriate technical and organizational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access. Only authorized personnel and third-party service providers have access to your personal data as necessary from time to time, and such employees and service providers are contractually obligated to treat such information as confidential.
How long we keep your personal data
We will retain your personal data for as long as necessary to fulfill the purpose for which we collected it, which may also be on an ongoing basis. E.g. if you are a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates in job placement for many years and potentially throughout their careers.
Some personal data are retained longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, secondary, accounting and reporting source obligations, the nature and amount of your personal data in our possession, and the potential risk from unauthorized use or disclosure of your personal data.
When we process your personal data for direct marketing purposes, we will do so until your request to cease such processing, which will continue for a short period following such a request (to enable us to comply with it). We also keep track of your request not to send you direct marketing or to process your data indefinitely, so that we can comply with your request.
Your rights over the personal data we hold about you
You have several rights under European data protection law. These rights include the right to ask us for a copy of your personal data, to correct, delete, or restrict the processing of your personal data, to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (bring) such data to another data controller.
In addition, you can object to the processing of your personal data in certain circumstances (in particular, when we are not obliged to process your personal data to fulfill a contractual or legal requirement, or when we are using the data for direct marketing).
These rights may be limited, e.g., if fulfilling your request would involve disclosure of another person's personal data, infringement of the rights of third parties (including us), or if you ask us to delete information that we are required to retain by law or that we have legitimate compelling interests in retaining. We will inform you of any relevant exemptions we may invoke in responding to your request.
How to contact us
Exercising your rights
To exercise your rights, revoke your consent to processing or unsubscribe from receiving marketing communications from us, you can:
- email us at info@exphire.com
-
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 this Application depends on the payment system used.
Cookie Policy
This Application 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 to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Data transfer abroad based on standard contractual clauses
If this is the 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.
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for California consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).
Notice at collection
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information, biometric information, internet or other electronic network activity information, geolocation data, audio, electronic, visual, thermal, olfactory, or similar information, employment related information and inferences drawn from other personal information.
We have collected the following categories of sensitive personal information: Biometric Data access permission, username, username, username, password, VAT Number, VAT Number, Tax ID and payment info
We will not collect additional categories of personal information without notifying you.
Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it
You have the right to request that we limit the 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.
We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.
Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.
To fully exercise your right to limit the use or disclosure of your sensitive personal information you can contact us at any time, using the contact details provided in this document.
For a simplified method you can also use the privacy choices link provided on this Application.
We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.
Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “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 or not 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 CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of 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 cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. 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 it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the VCDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission, VAT Number, VAT Number and Tax ID
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Application.
Please note that certain exceptions set forth in the VCDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
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 need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, 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.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the CPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission, VAT Number, VAT Number and Tax ID
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Application.
Please note that certain exceptions set forth in the CPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
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 need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the CTDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission, VAT Number, VAT Number and Tax ID
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Application. In the event of withdrawal, we will stop processing the relevant data as soon as possible, but no later than 15 days after receiving your withdrawal request.
Please note that certain exceptions set forth in the CTDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
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 need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the UCPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information
With your consent, we collect the following categories of sensitive data: Biometric Data access permission, VAT Number, VAT Number and Tax ID
You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Application.
Please note that certain exceptions set forth in the UCPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
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 need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
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 Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
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 this Application, if not stated otherwise within this document.