Privacy Policy of VYBZ

Full policy

Owner and Data Controller

VYBZ Inc.
24 Dering Street
London W1S 1BL
United Kingdom

Owner contact email: support@vybzapp.com

Types of Data collected

Among the types of Personal Data that VYBZ collects, by itself or through third parties, there are: username; Data communicated while using the service; Tracker; Usage Data; Universally unique identifier (UUID); Crash information; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; app information; device logs; country; first name; last name; phone number; gender; website; various types of Data; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Sensors permission; SMS permission; Storage permission; Bluetooth sharing permission; Social media accounts permission; NFC Reader permission ; Biometric Data access permission; Photo Library permission; Siri permission; Apple's speech recognition servers permission; Call permission; Camera permission, without saving or recording; general activity data; geographic position; screenshots; date of birth; address; password; VAT Number; company name; Tax ID; profession; state; number of employees; profile picture; social media accounts ; User ID; picture; academic background; shopping history; mouse movements; motion sensor events; answers to questions; Data communicated in order to use the Service; scroll position; keypress events; touch events.

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

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 VYBZ (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: Access to third-party accounts, Registration and authentication, Analytics, Infrastructure monitoring, Displaying content from external platforms, Beta Testing, Contacting the User, Content commenting, Content performance and features testing (A/B testing), Data transfer outside the EU, Device permissions for Personal Data access, Social features, Handling activity data, Handling payments, Handling productivity related activity , Heat mapping and session recording, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Managing data collection and online surveys, Managing landing and invitation pages, Managing support and contact requests, Platform services and hosting, Registration and authentication provided directly by VYBZ, Remarketing and behavioral targeting, SPAM protection, Tag Management, Traffic optimization and distribution, User database management and Advertising.

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, VYBZ 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 VYBZ.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by VYBZ.

Apple's speech recognition servers permission

Used for sending the User's Data to Apple's speech recognition servers.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. VYBZ 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. VYBZ 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 VYBZ 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.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Camera permission, without saving or recording

Used for accessing the camera or capturing images and video from the device.
VYBZ does not save or record the camera output.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

NFC Reader permission

Allows VYBZ to read contact-less tags.

Photo Library permission

Allows access to the User's Photo Library.

Precise location permission (continuous)

Used for accessing the User's precise device location. VYBZ may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. VYBZ 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 VYBZ to derive the exact position of the User on a continuous basis.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

Siri permission

Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

  This type of service allows VYBZ to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  Twitter account access (X Corp.)

  This service allows VYBZ to connect with the User's account on the Twitter social network, provided by Twitter, Inc.

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

  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 the United States

• 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 VYBZ, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside VYBZ. 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.

  Location Sciences (Location Sciences AI Ltd)

  Location Sciences is an advertising service provided by Location Sciences AI Ltd.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United Kingdom – 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

• 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.

  MixPanel (MixPanel)

  MixPanel is an analytics service provided by Mixpanel Inc.

  Personal Data processed: Tracker; Usage Data.

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

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

  This processing constitutes:

  • a Sale in the United States

  Google Analytics (Universal Analytics) (Google LLC)

  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 VYBZ, 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: Tracker; 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

  Google Analytics Advertising Reporting Features (Google LLC)

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

  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

  Google Analytics (Universal Analytics) with anonymized IP (Google LLC)

  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 VYBZ, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

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

  Personal Data processed: Trackers; Usage Data.

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

• Beta Testing

  This type of service makes it possible to manage User access to VYBZ, or parts of it, for the purpose of testing a certain feature or the entire Application.
  The service provider may automatically collect data related to crashes and statistics related to the User's use of VYBZ in a personally identifiable form.

  App Center (Microsoft Corporation)

  App Center is a beta testing service provided by Microsoft Corporation. VYBZ may also send push notifications to the User.

  Personal Data processed: Data communicated while using the service; email address; 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

  Beta by Crashlytics (Google LLC)

  Beta by Crashlytics is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: app information; device information; device logs; Tracker; 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: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Google Play Beta Testing (Google LLC)

  Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Data communicated while using the service; device information; device logs; Tracker; 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: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  TestFlight (Apple Inc.)

  TestFlight is a beta testing service provided by Apple Inc.

  Personal Data processed: app information; country; Data communicated while using the service; device information; device logs; email address; Tracker; 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; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Contacting the User

  Contact form (VYBZ)

  By filling in the contact form with their Data, the User authorizes VYBZ 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: email address; first name; last name; phone number.

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

  This processing constitutes:

  Phone contact (VYBZ)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to VYBZ, 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:

  Mailing list or newsletter (VYBZ)

  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 VYBZ. Your email address might also be added to this list as a result of signing up to VYBZ or after making a purchase.

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

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

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of VYBZ.
  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 (VYBZ)

  VYBZ has its own internal content comment system.

  Personal Data processed: email address; first name; last name; phone number; Tracker; Usage Data; username; website.

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

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island 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 VYBZ.

  Google Optimize (Google LLC)

  Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").

  Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Tracker; 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

  Optimizely (Optimizely, Inc.)

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

  Personal Data processed: Tracker; 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 Optimize 360 (Google LLC)

  Google Optimize 360 is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").

  This service allows the Owner to target groups of Users on the base of their past use of VYBZ. 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: Tracker; 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

  Firebase Remote Config (Google LLC)

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

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

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

  This processing constitutes:

  • a Sale in California

• Device permissions for Personal Data access

  VYBZ requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (VYBZ)

  VYBZ 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: Apple's speech recognition servers permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Bluetooth sharing permission; Call permission; Camera permission; Camera permission, without saving or recording; Contacts permission; Microphone permission; NFC Reader permission ; Photo Library permission; Precise location permission (continuous); Precise location permission (non-continuous); Sensors permission; Siri permission; SMS permission; Social media accounts permission; Storage permission.

  Category of Personal Information collected according to the CCPA: biometric information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, thermal, olfactory, or similar information.

  This processing constitutes:

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of VYBZ and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google LLC)

  Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows VYBZ 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; 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 LLC)

  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 VYBZ 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

• Handling activity data

  This type of service allows the Owner to use the activity data collected by your device in order for VYBZ to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
  Depending on what is described below, third parties may be involved in the activity tracking.
  Most devices allow for the User to control which Data is accessed or stored.

  Activity data tracked by your device (VYBZ)

  VYBZ uses some activity data tracked by your device to operate or to provide specific features.

  Personal Data processed: general activity data.

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

  This processing constitutes:

• Handling payments

  Unless otherwise specified, VYBZ 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. VYBZ 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.

  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: 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: internet or other electronic network activity information.

  This processing constitutes:

  PayPal (PayPal Inc.)

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

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

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

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

  This processing constitutes:

  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

• Handling productivity related activity

  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.

  Gmail (Google LLC)

  Gmail is a service that manages email communication provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.

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

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

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

  This processing constitutes:

• Heat mapping and session recording

  Heat mapping services are used to display the areas of VYBZ 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.

  Hotjar Heat Maps & Recordings (Hotjar Ltd.)

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

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

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

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

  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 VYBZ to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of VYBZ.

  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; Canada – Privacy Policy; Brazil – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy; India – Privacy Policy; Australia – Privacy Policy; China – Privacy Policy; Italy – Privacy Policy; Bahrain – Privacy Policy.

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

  This processing constitutes:

  Firebase Cloud Firestore (Google LLC)

  Firebase Cloud Firestore is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  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; Ireland – Privacy Policy.

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

  This processing constitutes:

  Firebase Cloud Functions (Google LLC)

  Firebase Cloud Functions is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  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; Ireland – Privacy Policy.

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

  This processing constitutes:

  Firebase Cloud Storage (Google LLC)

  Firebase Cloud Storage is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  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; Ireland – Privacy Policy.

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

  This processing constitutes:

  Google App Engine (Google LLC)

  Google App Engine is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

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

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

  This processing constitutes:

  Google BigQuery (Google LLC)

  Google BigQuery is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

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

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

  This processing constitutes:

  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; European Union – Privacy Policy; Ireland – Privacy Policy; Germany – Privacy Policy; Australia – Privacy Policy; Japan – Privacy Policy.

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

  This processing constitutes:

  MongoDB Cloud (MongoDB, Inc.)

  MongoDB Cloud is a hosting and backend service provided by MongoDB, Inc.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  Vuforia (PTC, Inc)

  Vuforia is a hosting and backend service provided by PTC, 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: internet or other electronic network activity information.

  This processing constitutes:

  Google Cloud Storage (Google LLC)

  Google Cloud Storage is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

  Place of processing: Canada – Privacy Policy; Brazil – Privacy Policy; Belgium – Privacy Policy; Germany – Privacy Policy; Netherlands – Privacy Policy; Japan – Privacy Policy; India – Privacy Policy; Australia – Privacy Policy; Ireland – Privacy Policy.

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

  This processing constitutes:

• Infrastructure monitoring

  This type of service allows VYBZ 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 VYBZ.

  Crashlytics (Google LLC)

  Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  Personal Data processed: Crash information; device information; Universally unique identifier (UUID).

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

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

  This processing constitutes:

  Instabug (Instabug, Inc.)

  Instabug is a monitoring service provided by Instabug, Inc.

  Personal Data processed: app information; country; device information; device logs; email address; first name; geographic position; phone number; screenshots; Tracker; 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; internet or other electronic network activity information; geolocation data.

  This processing constitutes:

  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.

  This processing constitutes:

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of VYBZ, in order to contact and be contacted by VYBZ‘s support service.
  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. Moreover, live chat conversations may be logged.

  Zendesk Chat (Zendesk, Inc.)

  Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.

  Personal Data processed: Data communicated while using the service; email address; first name; last name; phone number; Tracker; 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

• Location-based interactions

  Geolocation (VYBZ)

  VYBZ 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 VYBZ.

  Personal Data processed: 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, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
  • a Sharing in California
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

  Non-continuous geolocation (VYBZ)

  VYBZ 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 VYBZ.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

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

  This processing constitutes:

• 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.

  Sendgrid (Sendgrid)

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

  Personal Data processed: country; date of birth; email address; first name; gender; last name; phone number; Tracker; Usage Data; username.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  • a Sale in the United States
  • a Sharing in California

  Twilio (Twilio, Inc.)

  Twilio is a phone numbers management and communication service provided by Twilio, Inc.

  Personal Data processed: phone number.

  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

  Mailchimp (The Rocket Science Group LLC)

  Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: various types of Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  • a Sale in the United States
  • a Sharing in California

  Firebase Notifications (Google LLC)

  Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

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

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

  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

  Firebase Cloud Messaging (Google LLC)

  Firebase Cloud Messaging is a message sending service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

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

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

  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

  Customer.io (Peaberry Software Inc.)

  Customer.io is an email address management and message sending service provided by Peaberry Software Inc.

  Personal Data processed: email address; 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.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Managing data collection and online surveys

  This type of service allows VYBZ 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.

  SurveyMonkey (SurveyMonkey Inc.)

  SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Inc., SurveyMonkey Brasil Internet Ltda. or by SurveyMonkey Europe UC, depending on how the Owner manages the Data processing.

  Personal Data processed: address; company name; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; number of employees; password; phone number; profession; state; Tax ID; Tracker; Usage Data; username; VAT Number; website.

  Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; European Union – 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; employment related information; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California

  Typeform (TYPEFORM S.L)

  Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

  Personal Data processed: country; date of birth; email address; first name; gender; geographic position; last name; phone number; profession; Trackers; Usage Data; username; various types of Data as specified in the privacy policy of the service.

  Place of processing: Spain – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

• Managing landing and invitation pages

  This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
  Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

  Unbounce (Unbounce Marketing Solutions Inc.)

  Unbounce is a landing page management service provided by Unbounce Marketing Solutions Inc., that allows VYBZ to collect the email addresses of Users interested in its service.
  Unbounce allows 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 the created landing pages.

  Personal Data processed: email address; Tracker; Usage Data.

  Place of processing: Canada – 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

• Managing support and contact requests

  This type of service allows VYBZ 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: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

  Salesforce Service Cloud (Salesforce.com, inc.)

  Salesforce Service Cloud is a support and contact request management service provided by salesforce.com, inc.

  Personal Data processed: Data communicated while using the service; 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: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California

• Platform services and hosting

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

  Apple App Store (Apple Inc.)

  VYBZ is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

  By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of VYBZ. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  Squarespace (Squarespace, Inc)

  Squarespace is a platform provided by Squarespace, Inc. that allows the Owner to build, run and host VYBZ. Squarespace is highly customizable and can host websites from simple blogs to complex e-commerce platforms.

  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: internet or other electronic network activity information.

  This processing constitutes:

  Google Play Store (Google LLC)

  VYBZ is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

  By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: 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:

• Registration and authentication

  By registering or authenticating, Users allow VYBZ 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, VYBZ 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.

  Instagram Authentication (Facebook, Inc.)

  Instagram Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Instagram social network.

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

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

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

  This processing constitutes:

  • a Sale in California

  Firebase Authentication (Google LLC)

  Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

  Personal Data processed: email address; first name; last name; password; phone number; profile picture; social media accounts ; username.

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

  Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; audio, electronic, visual, thermal, olfactory, or similar information.

  This processing constitutes:

  Google OAuth (Google LLC)

  Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.

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

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

  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

  Facebook Authentication (Facebook, Inc.)

  Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

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

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

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

  This processing constitutes:

  • a Sale in California

  Sign in with Apple (Apple Inc.)

  Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.

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

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  Twitter OAuth (X Corp.)

  Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

  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: internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in the United States

• Registration and authentication provided directly by VYBZ

  By registering or authenticating, Users allow VYBZ 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 (VYBZ)

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

  Personal Data processed: academic background; date of birth; email address; first name; gender; last name; phone number; picture; profile picture; Usage Data; User ID; username; various types of Data.

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

  This processing constitutes:

  • a Sale in California

• Remarketing and behavioral targeting

  This type of service allows VYBZ and its partners to inform, optimize and serve advertising based on past use of VYBZ 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.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of VYBZ with the Facebook advertising network.

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

  Personal Data processed: email address; Tracker.

  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

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of VYBZ with the Facebook advertising network.

  Personal Data processed: Tracker; 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 Ad Manager Audience Extension (Google LLC)

  Google Ad Manager Audience Extension 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 tracks the visitors of VYBZ and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data processed: Tracker; 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 LLC)

  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 VYBZ with the Google Ads advertising network and the DoubleClick Cookie.

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

  Personal Data processed: Tracker; 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 Signals (Google LLC)

  VYBZ uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from VYBZ 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: Tracker; 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

  Salesforce Audience Studio (Salesforce.com, inc.)

  Salesforce Audience Studio is a remarketing and behavioral targeting service provided by Salesforce.com, inc.
  Salesforce Audience Studio 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. Salesforce Audience Studio 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 Salesforce Audience Studio may be including.

  Personal Data processed: Tracker; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Twitter Remarketing (X Corp.)

  Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of VYBZ with the Twitter advertising network.

  Personal Data processed: Tracker; 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

  Twitter Tailored Audiences (X Corp.)

  Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of VYBZ with the Twitter advertising network.

  Users can opt out from interest-based ads by going to: Personalization and Data.

  Personal Data processed: email address; Tracker.

  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
  • a Sharing in California

  Remarketing with Google Analytics (Google LLC)

  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 Cookies with the Google Ads advertising network and the Doubleclick Cookie.

  Personal Data processed: Tracker; 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

  LinkedIn Website Retargeting (LinkedIn Corporation)

  LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of VYBZ with the LinkedIn advertising network.

  Personal Data processed: Tracker; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  AdRoll (NextRoll, Inc.)

  AdRoll is an advertising service provided by NextRoll, Inc. AdRoll can serve targeted advertising on any device connected to the User, by processing their email address using a security technique called hashing.
  AdRoll may also automatically collect certain types of data to serve personalized recommendations to the User, as stated in its privacy policy.

  Personal Data processed: device information; shopping history; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of 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; commercial information; internet or other electronic network activity information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Rakuten Advertising Remarketing (Rakuten Marketing LLC)

  Rakuten Advertising Remarketing is a remarketing and behavioral targeting service provided by Rakuten Marketing LLC or by Rakuten Marketing LLC dba Rakuten Advertising, depending on how the Owner manages the Data processing, that connects the activity of VYBZ with the Rakuten advertising network.

  Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data.

  Place of processing: United States – Privacy Policy – Opt out; European Union – 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

• Social features

  Snapchat

  You can post Snaps from Snapchat app to your VYBZ Story.

  This processing constitutes:

  • a Sharing in California

  Twitter

  You can link your Twitter account with VYBZ and view and share your tweets with VYBZ App user community.

  This processing constitutes:

  • a Sharing in California

  Instagram

  You can link your Instagram account with VYBZ and view and share your instagram posts with VYBZ App user community.
  
  You can also share content to Instagram Stories and Feed directly from within VYBZ

  This processing constitutes:

  • a Sharing in California

  Firebase Dynamic Links (Google LLC)

  Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within VYBZ.

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

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

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

  This processing constitutes:

  • a Sale in California

  Firebase Invites (Google LLC)

  Firebase Invites is a social feature provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that enables Users to share VYBZ. The sharing may contain referral codes, or content from within VYBZ and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed VYBZ via invite.

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

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

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

  This processing constitutes:

  • a Sale in California

• SPAM protection

  This type of service analyzes the traffic of VYBZ, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA (Google LLC)

  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: Tracker; 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:

  hCaptcha (Intuition Machines, Inc)

  hCaptcha is a SPAM protection service provided by Intuition Machines, Inc.

  Personal Data processed: answers to questions; Data communicated in order to use the Service; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on VYBZ in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google LLC)

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

  Personal Data processed: 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

  Segment (Segment Inc.)

  Segment is a tag management service provided by Segment.io, Inc.

  Personal Data processed: Tracker; 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

  TagCommander (Fjord Technologies )

  TagCommander is a tag management service provided by Fjord Technologies or by Fjord Technologies SAS, depending on how the Owner manages the Data processing,

  Personal Data processed: Tracker; Usage Data.

  Place of processing: France – Privacy Policy; United Kingdom – 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

  Tealium IQ tag Management (Tealium Inc.)

  Tealium IQ tag Management is a tag management service provided by Tealium Inc.

  Personal Data processed: Tracker; 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

• Traffic optimization and distribution

  This type of service allows VYBZ 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 VYBZ and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare Inc.)

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

  Personal Data processed: Tracker; 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: 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 VYBZ, 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 VYBZ.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on VYBZ.

  Salesforce Sales Cloud (Salesforce.com, inc.)

  Salesforce Sales Cloud is a User database management 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: internet or other electronic network activity 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: email address; phone number; 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

  Intercom (Intercom Inc.)

  Intercom is a User database management service provided by Intercom Inc., Intercom R&D Unlimited Company, Intercom Software Australia Pty Ltd or by Intercom Software UK Limited, depending on how the Owner manages the Data processing.
  Intercom can also be used as a medium for communications, either through email, or through messages within VYBZ. Intercom Messenger may use Trackers to recognize and track Users behaviour.

  Personal Data processed: Data communicated while using the service; email address; Tracker; Universally unique identifier (UUID); 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; Australia – Privacy Policy; 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

  Marketo Lead Generation (Marketo, Inc.)

  Marketo Lead Generation is a User database management service provided by Marketo, Inc.

  Personal Data processed: email address; 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

  Braze (Braze, Inc.)

  Braze is a User database management service provided by Braze, 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: 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: 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: 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

• Non-continuous geolocation with extended notes

  If explicit authorization has been provided, the User’s location data may be tracked by VYBZ for 7 days for the "Neighbourhood" mode, and for 1 day for the "Around Me" mode, unless the user logs out of the app.

• Push notifications

  VYBZ may send push notifications to the User to achieve the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for VYBZ, some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of VYBZ.

• Push notifications based on the User's geographic location

  VYBZ may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of VYBZ.

• Unique device identification

  VYBZ may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

• User identification via a universally unique identifier (UUID)

  VYBZ may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. VYBZ may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. VYBZ adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within VYBZ, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

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

  The Owner may use the Personal and Usage Data collected through VYBZ to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
  The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

• Access the address book

  VYBZ may request access to your address book.

  
  
  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Push notifications for direct marketing

  VYBZ may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by VYBZ).

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for VYBZ or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of VYBZ.

  Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

• Rights for registered California Users under the age of 18

  California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

  If a registered User fits that description and posted content on VYBZ, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

  In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

• Global TCF v2 Cookie (euconsent-v2)

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

• iubenda CCPA Cookie (usprivacy)

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

• iubenda Consent Solution localStorage

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

• iubenda Cookie Solution (consent Cookie)

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

• iubenda Cookie Solution (remote consent Cookie)

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

• Preference Cookies

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

• sessionStorage

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

• Site specific TCF v2 Cookie (euconsent-v2)

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

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

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

Cookie Policy

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

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.

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 VYBZ and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymized personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorized by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Additional information for Users in Brazil

Transfer of personal information outside of Brazil based on contracts and other legal means

We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

To do so, we may use one of the following legal means:

• specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
• standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
• global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
• seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.

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

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

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

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running VYBZ 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, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island 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 VYBZ.

For example, you directly provide your Personal Information when you submit requests via any forms on VYBZ. You also provide Personal Information indirectly when you navigate VYBZ, 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 VYBZ 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, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island 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, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana 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. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, 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 VYBZ.

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

How and when we are expected to handle your request

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

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

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

Additional information for Users in the United States

CCPA: Collection of personal information about minors

We do not knowingly collect personal information of consumers who are below the age of 16.

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 VYBZ 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, VYBZ 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, VYBZ and any third-party services may collect files that record interaction with VYBZ (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 VYBZ 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.