Privacy Policy of Babe Hair Extensions

Owner and Data Controller

Beauty Industry Group and its Affiliates
1250 N. Flyer Way, Suite 100
Salt Lake City, UT 84116
Affiliates include: Bellami, Beauty Works, Babe, Zala, Luxy, Glam Seamless, Donna Bella, Halo, Hairtalk, Hidden Crown, and Hotheads

Owner contact email: info@babehairextensions.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: first name; last name; gender; date of birth; phone number; company name; profession; physical address; fax number; country; state; county; email address; ZIP/Postal code; various types of Data; city; field of activity; User ID; number of employees; website; Usage Data; Trackers; username; purchase history; number of Users; device information; session statistics; latitude (of city); longitude (of city); browser information; billing address; shipping address; payment info; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); session duration; scroll-to-page interactions; clicks; time zone; mouse movements; interaction events; diagnostic events; page events; custom events; layout details; positional information; answers to questions; Data communicated while using the service; geographic position; coarse location; keypress events; motion sensor events; scroll position; touch events; house number; data relating to the point of sale; workplace; contact info; name; social media accounts ; profile picture; user content; Data communicated in order to use the Service; language; picture; screenshots; page views.

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: Contacting the User, User database management, Analytics, Displaying content from external platforms, Tag Management, Traffic optimization and distribution, Managing contacts and sending messages, Platform services and hosting, Advertising, Remarketing and behavioral targeting, Handling payments, Heat mapping and session recording, Infrastructure monitoring, Interaction with data collection platforms and other third parties, Location-based interactions, SPAM protection, Selling goods and services online, Registration and authentication provided directly by this Application, Registration and authentication, Managing support and contact requests, Managing data collection and online surveys, Interaction with support and feedback platforms, Hosting and backend infrastructure, Content commenting, Connecting Data, Collection of privacy-related preferences and Content performance and features testing (A/B testing).

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be 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.

  TikTok conversion tracking (TikTok Inc.)

  TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on this Application. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of this Application.

  Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Meta ads conversion tracking (Meta pixel)

  Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, 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: United States – Privacy Policy – Opt out; 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 in California

  X Ads conversion tracking (X Corp.)

  X Ads conversion tracking is an analytics service provided by X Corp. that connects data from the X advertising network with actions performed on this Application.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Ad Manager

  Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  In order to understand Google's use of Data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.  

  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• 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 Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“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.

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

  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: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data.

  This processing constitutes:

  • a Sale in California

  Meta Events Manager

  Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited or by Meta Platforms, Inc., depending on how the Owner manages the Data processing. 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 – Opt out; United States – Privacy Policy – Opt out.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Analytics collected directly (this Application)

  This Application uses an internal analytics system that does not involve third parties.

  Personal Data processed: Trackers; Usage Data.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Analytics (Universal Analytics)

  Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“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 order to understand Google's use of Data, consult Google's partner policy.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; 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 in the United States

• 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 Consent Database (iubenda srl)

  The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
  In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

  Personal Data processed: Data communicated while using the service; Trackers.

  Place of processing: Italy – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  iubenda Privacy Controls and Cookie Solution (iubenda srl)

  The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on 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.

• Connecting Data

  This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.
  This results in Data flowing through these services, potentially causing the retention of this Data.

  Zapier (Zapier, Inc.)

  Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.

  Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; language; last name; phone number; picture; profession; screenshots; Usage Data; username; ZIP/Postal code.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; audio, electronic, visual, thermal, olfactory, or similar information; employment related information; inferences drawn from other personal information.

• 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; fax number; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; Trackers; Usage Data; User ID; various types of Data; website; ZIP/Postal code.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

  This processing constitutes:

  • a Sale in California

  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; date of birth; email address; first name; last name; phone number; physical address; profession; state; Trackers; Usage Data; website; ZIP/Postal code.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

  This processing constitutes:

  • a Sale in the United States

  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:

  • a Sale in California

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of this Application.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (this Application)

  This Application has its own internal content comment system.

  Personal Data processed: email address; first name; last name; Trackers; Usage Data; username.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in the United States
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana

• 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.

  Optimizely (Optimizely, Inc.)

  Optimizely is an A/B testing service provided by Optimizely, Inc.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• 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 Fonts

  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Maps widget

  Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Adobe Fonts (Adobe Systems Incorporated)

  Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows this Application to incorporate content of this kind on its pages.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  YouTube Data API

  YouTube Data API is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate functions normally executed on YouTube so that Users can watch, find, and manage YouTube content directly on this Application.

  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.

  Place of processing: United States – Privacy Policy – Opt out; 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 in California

  YouTube IFrame Player

  YouTube IFrame Player is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, 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.

  Place of processing: United States – Privacy Policy – Opt out; 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 in California

• Handling payments

  Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  PayPal (PayPal Inc.)

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

  Personal Data processed: billing address; device information; email address; first name; last name; payment info; phone number; purchase history; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.

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

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana

  Google Pay

  Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

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

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  By POS (Banco Popolare Soc. Coop.)

  By POS is a payment service provided by Banco Popolare Soc. Coop.

  Personal Data processed: billing address; email address; first name; last name; phone number; purchase history; shipping address; Trackers; Usage Data; 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: identifiers; commercial information; internet or other electronic network activity information.

  Apple Pay (Apple Inc.)

  Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

  Personal Data processed: billing address; email address; first name; last name; phone number; purchase history; shipping address; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  Amazon Payments (Amazon)

  Amazon Payments is a payment service provided by Amazon.com, Inc., which allows Users to make online payments using their Amazon credentials.

  Personal Data processed: billing address; email address; first name; last name; phone number; purchase history; shipping address; Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.

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

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

• 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.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data.

  This processing constitutes:

  • a Sale in California

• 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.

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Google BigQuery (Google LLC)

  Google BigQuery is a hosting and backend service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Heroku (Salesforce.com, Inc.)

  Heroku is a hosting service provided by Salesforce.com, Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Google Cloud Storage (Google LLC)

  Google Cloud Storage is a hosting service provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  Microsoft Azure (Microsoft Corporation)

  Microsoft Azure is a hosting service provided by Microsoft Corporation.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  accessiBe accessWidget (accessiBe Ltd.)

  accessiBe accessWidget is a service that helps websites to comply with accessibility standards and is provided by accessiBe Ltd.

  Personal Data processed: browser information; clicks; interaction events; page views.

  Place of processing: Israel – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sharing in California

• Infrastructure monitoring

  This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

  Sentry (Functional Software, Inc. )

  Sentry is a monitoring service provided by Functional Software, Inc. .

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

• 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.

  Google Forms (embedded) (Google LLC)

  Google Forms (embedded) is a service for interacting with the Google data collection platform provided by Google LLC.

  Personal Data processed: answers to questions; company name; country; Data communicated while using the service; date of birth; email address; first name; last name; phone number; physical address; state; Trackers; Usage Data; username; ZIP/Postal code.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Interaction with support and feedback platforms

  This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Application.
  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.

  Zendesk Widget (Zendesk, Inc.)

  The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

  Personal Data processed: company name; country; date of birth; email address; first name; last name; phone number; physical address; Trackers; Usage Data; username.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Location-based interactions

  Geolocation (this Application)

  This Application may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.

  Personal Data processed: coarse location; geographic position.

  Category of Personal Information collected according to the CCPA: geolocation data.

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
  • a Sharing in California
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana

• 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.

  Klaviyo (Klaviyo Inc.)

  Klaviyo is an email address management and message sending service provided by Klaviyo Inc.

  To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

  Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; profession; purchase history; state; Trackers; Usage Data; username; various types of Data.

  Place of processing: United States – Privacy Policy – Opt out.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Amazon Simple Email Service (SES) (Amazon)

  Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• 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.

  Klaviyo Forms (Klaviyo Inc.)

  Klaviyo Forms is a form builder and data collection platform provided by Klaviyo Inc.

  To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

  Personal Data processed: city; company name; Data communicated while using the service; date of birth; email address; first name; last name; phone number; physical address; profession; purchase history; state; Trackers; Usage Data; username.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

  This processing constitutes:

  • a Sale in California

  Google Forms (Google LLC)

  Google Forms is a form builder and data collection platform provided by Google LLC.

  Personal Data processed: answers to questions; city; company name; contact info; Data communicated while using the service; date of birth; email address; first name; last name; phone number; physical address; profession; state; Trackers; Usage Data; username; workplace; ZIP/Postal code.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California

  Data provided via online forms, managed directly (this Application)

  This Application makes use of online forms that can be used to collect Data about Users.

  Personal Data processed: answers to questions; city; company name; contact info; date of birth; email address; first name; last name; name; phone number; physical address; profile picture; social media accounts ; Trackers; Usage Data; user content; workplace.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; audio, electronic, visual, thermal, olfactory, or similar information; employment related information; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California

  JotForm (JotForm Inc.)

  JotForm is a form builder and data collection platform provided by JotForm Inc.

  Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; number of employees; phone number; physical address; state; Trackers; Usage Data; username; website.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Managing support and contact requests

  This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  Zendesk (Zendesk, Inc.)

  Zendesk is a support and contact request management service provided by Zendesk Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a Sale in California

• 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.

  Shopify

  Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.

  Personal Data processed: billing address; device information; email address; first name; last name; payment info; phone number; shipping address; Trackers; Usage Data.

  Place of processing: Canada – Privacy Policy; Singapore – Privacy Policy; Ireland – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

• Registration and authentication

  By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Direct registration and profiling (this Application)

  By registering or authenticating directly through this Application, Users allow this Application to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.

  Personal Data processed: billing address; company name; data relating to the point of sale; date of birth; email address; first name; house number; last name; number of employees; phone number; physical address; shipping address; state; Trackers; Usage Data; User ID; username; various types of Data; ZIP/Postal code.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Registration and authentication provided directly by this Application

  By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (this Application)

  The User registers by filling out the registration form and providing the Personal Data directly to this Application.

  Personal Data processed: country; date of birth; email address; field of activity; first name; house number; last name; number of employees; phone number; physical address; state; Trackers; Usage Data; User ID; username; various types of Data; ZIP/Postal code.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

• 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.

  TikTok Remarketing ( TikTok Information Technologies UK Limited )

  TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of this Application with the TikTok advertising network.

  Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

  Place of processing: United Kingdom – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Criteo Dynamic Retargeting (Criteo SA)

  Criteo Dynamic Retargeting is a remarketing and behavioral targeting service provided by Criteo SA., that connects the activity of this Application with the Criteo advertising network.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Facebook Remarketing

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Meta Audience Network.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; 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 in California
  • a Sharing in California

  Google Ads Remarketing

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, 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: United States – Privacy Policy – Opt Out; 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 in California
  • a Sharing in California

  Klaviyo segmentation and social advertising (Klaviyo Inc.)

  Klaviyo segmentation and social advertising is a remarketing and behavioral targeting service provided by Klaviyo Inc.

  Klaviyo segmentation and social advertising makes use of tracking technologies to monitor User behavior. This Data is then used to personalize the User's experience and to provide targeted advertising. Klaviyo segmentation and social advertising may also connect the collected Data with other networks, including advertising networks, and enable these parties to track and target the User. The Owner, unless otherwise specified in this document, has no direct relationship with the third parties that Klaviyo segmentation and social advertising may be including.

  To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

  Personal Data processed: device information; email address; purchase history; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – Opt out.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Meta Custom Audience

  Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Meta Audience Network.

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

  Personal Data processed: email address; Trackers.

  Place of processing: United States – Privacy Policy – Opt out; 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 in California
  • a Sharing in California

  Remarketing with Google Analytics

  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, 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: United States – Privacy Policy – Opt Out; 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 in California
  • a Sharing in California

  Twitter Remarketing (X Corp.)

  Twitter Remarketing is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of this Application with the Twitter advertising network.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• 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.

  ShipStation (ShipStation)

  ShipStation is a shipping management service provided by ShipStation. This allows the Owner to let Users track their orders, but also to organize returns and inventory.

  Personal Data processed: billing address; device information; email address; first name; last name; phone number; shipping address; Trackers; Usage Data.

  Place of processing: United States – Privacy Policy – https://info.shipstation.com/ccpa.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

• 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 reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

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

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.

• 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 Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Trackers; Usage Data.

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

  Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

• 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 in California
  • a Sharing in California

  Cloudflare (Cloudflare Inc.)

  Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.

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

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• 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.

  Klaviyo CRM (Klaviyo Inc.)

  Klaviyo CRM is a User database management service provided by Klaviyo Inc.

  Klaviyo CRM can also be used as a medium for communications, either through email, or through messages within this Application.

  To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

  Personal Data processed: city; company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; profession; purchase history; state; Trackers; Usage Data; username; various types of Data.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.

  This processing constitutes:

  • a Sale in California

  HubSpot CRM (HubSpot, Inc.)

  HubSpot CRM is a User database management service provided by HubSpot, Inc.

  Personal Data processed: company name; country; email address; first name; gender; last name; phone number; physical address; purchase history; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Salesforce Marketing Cloud (Salesforce.com, Inc.)

  Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.

  Personal Data processed: Data communicated while using the service; email address; first name; last name; phone number; Trackers; Usage Data; User ID; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

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

• localStorage

  localStorage allows this Application to store and access data right in the User's browser with no expiration date.

• Preference Cookies

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

• Selling goods and services online

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

Cookie Policy

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

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 Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
• the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
• the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
• the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
• The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have

• The right to opt out of the processing of your Personal Information for Targeted Advertising;
• The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.