Privacy Policy of miasakurai.com/

Owner and Data Controller

Mia Sakurai

Owner contact email: privacy@miasakurainonihongo.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data; Trackers; email address; first name; last name; various types of Data; User ID; Data communicated while using the service; country; county; name; geographic position; number of Users; city; device information; session statistics; latitude (of city); longitude (of city); browser information; username; phone number; answers to questions; user content; contents of the email or message; profile picture; date of the message; time the message was sent; sender of the message; physical address; date of birth; language; password; ZIP/Postal code; payment info; billing address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); order ID; user subscriptions; browsing history; clicks; page views; state; IP address; Full access; Read only access; Read metadata; Modify; Insert and import; Compose; Basic settings management; Sensitive settings management; purchase history; province; metro area; geography/region; app information; device logs; operating systems; time zone; invoicing information; product interaction; customer support; interaction events; custom events; login history; primary account information; in-app messages ; keypress events; motion sensor events; mouse movements; scroll position; touch events; launches; number of sessions; session duration; scroll-to-page interactions; video views; search history; page events; Application opens; Universally unique identifier (UUID); Data communicated in order to use the Service; precise location; coarse location; gender; Tax ID; house number.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

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: Displaying content from external platforms, Advertising, Hosting and backend infrastructure, Contacting the User, Analytics, Managing contacts and sending messages, Platform services and hosting, Registration and authentication provided directly by this Website, Managing data collection and online surveys, Location-based interactions, Interaction with data collection platforms and other third parties, Collection of privacy-related preferences, Tag Management, Content performance and features testing (A/B testing), SPAM protection, Traffic optimization and distribution, Interaction with live chat platforms, Connecting Data, Handling activities related to productivity, Managing support and contact requests, Handling payments, Registration and authentication, Building and running this Website, Handling activities related to compliance and Remarketing and behavioral targeting.

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

Detailed information on the processing of Personal Data

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

• Advertising

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

  Query Click (Query Click Limited)

  Query Click is an advertising service provided by Query Click Limited.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: 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
  • a Sharing in California

  Direct Email Marketing (DEM) (this Website)

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

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

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

  This processing constitutes:

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

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

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

  Personal Data processed: Trackers; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California

  WhatsApp Business direct marketing (Meta Platforms Ireland Limited)

  This Website may send WhatsApp messages to the User for the purpose of direct marketing.
  Users may in most cases opt out of receiving direct marketing messages by tapping the opt out of marketing messages button in the chat.

  Personal Data processed: answers to questions; contents of the email or message; Data communicated while using the service; date of the message; first name; last name; phone number; profile picture; sender of the message; time the message was sent; user content.

  Place of processing: 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; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Videobyte (Videobyte Inc)

  Videobyte is an advertising service provided by Videobyte Inc.

  Personal Data processed: Trackers; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Videology (Videology, Inc.)

  Videology is an advertising service provided by Videology, Inc.

  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.

  Video Reach (Reach Media GmbH)

  Video Reach is an advertising service provided by Reach Media GmbH.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Germany – 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

  Meta Lookalike Audience (Meta Platforms Ireland Limited)

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

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

  Personal Data processed: Trackers; Usage Data.

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

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

• Analytics

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

  Google Analytics (Universal Analytics) 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 this Website, 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

  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 this Website, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

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

  Personal Data processed: Trackers; Usage Data.

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

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

  This processing constitutes:

  • a Sale in the United States

  MonterInsights

  This application is used to integrate Google Analitycs and monitors how visitors manage to find the site, measures and analyzes site traffic, collect the number of people who visited the site and where they came from in reports, and ranks the most and least viewed pages on the site, monitors unique and non-unique visitors and their nationality.

  This processing constitutes:

  • a Sharing in California

  Google Analytics 4 (Google LLC)

  Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

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

  Personal Data processed: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California

  User ID extension for Google Analytics (Google Ireland Limited)

  Google Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
  The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website.
  The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

  Personal Data processed: Trackers.

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

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

  This processing constitutes:

  • a Sale in California

  Google Analytics Advertising Reporting Features (Google Ireland Limited)

  Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

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

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

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

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

  This processing constitutes:

  • a Sale in California

  Meta Events Manager (Meta Platforms Ireland Limited)

  Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Website.

  Personal Data processed: billing address; browser information; browsing history; city; clicks; country; Data communicated while using the service; date of birth; email address; first name; IP address; last name; order ID; page views; payment info; phone number; state; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID; user subscriptions; ZIP/Postal code.

  Place of processing: 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

  WordPress Stats (Aut O’Mattic A8C Ireland Ltd.)

  WordPress Stats is an analytics service provided by Aut O’Mattic A8C Ireland Ltd.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

  YouTube Analytics and Reporting API (Google Ireland Limited)

  YouTube Analytics and Reporting API is a video content analytics service provided by Google Ireland Limited.

  Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

  Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

  Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Trackers; Usage Data; User ID; username.

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

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

  Cloudflare Web Analytics (Cloudflare, Inc.)

  Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare, Inc. that gives the Owner insight into the use of this Website by Users without needing to identify them. Further information may be found here and within the service's privacy policy.

  Personal Data processed: device information; language; 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:

  • a Sale in California

  Analytics collected directly (this Website)

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

  Personal Data processed: Trackers; Usage Data.

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

• Building and running this Website

  Key components of this Website are built and run directly by the Owner by making use of the software listed below.

  WordPress (self-hosted) (this Website)

  This Website is built and run by the Owner via a CMS software (Content Management System) called WordPress.

  Personal Data processed: billing address; city; country; Data communicated while using the service; date of birth; device information; email address; first name; language; last name; payment info; phone number; purchase history; Usage Data; ZIP/Postal code.

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

  This processing constitutes:

  • a Sharing in California

• Collection of privacy-related preferences

  This type of service allows this Website to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

  iubenda Cookie Solution (iubenda srl)

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

  Personal Data processed: Trackers.

  Place of processing: Italy – Privacy Policy.

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

  This processing constitutes:

• Connecting Data

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

  Zapier (Zapier, Inc.)

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

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

  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; inferences drawn from other personal information.

• Contacting the User

  Mailing list or newsletter (this Website)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

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

  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

  Contact form (this Website)

  By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: email address; first name; last name; Trackers; Usage Data; User ID; various types of Data.

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

  This processing constitutes:

  Phone contact (this Website)

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

  Personal Data processed: phone number.

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

  This processing constitutes:

  • a Sale in California

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.

  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: Trackers; Usage Data.

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

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

  This processing constitutes:

  • a Sale in California

  Google 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 this Website. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.

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

  Personal Data processed: Trackers; Usage Data.

  Place of processing: 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

• Displaying content from external platforms

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

  Google Fonts (Google LLC)

  Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

  Adobe Fonts (Adobe Systems Incorporated)

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

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

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

  YouTube video widget (Google Ireland Limited)

  YouTube is a video content visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

  Zapier widget (Zapier, Inc.)

  This Website embeds a widget provided by Zapier, 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:

  • a Sale in California

  YouTube video widget (Privacy Enhanced Mode) (Google Ireland Limited)

  YouTube is a video content visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
  This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on this Website unless they play the video.

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

  Place of processing: Ireland – Privacy Policy.

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

• Handling activities related to compliance

  This type of service allows this Website to handle activities related to compliance.

  iubenda Whistleblowing Management Tool (iubenda srl)

  The iubenda Whistleblowing Management Tool allows for the processing, storage, and retrieval of Users' reports regarding wrongdoing or misconduct.

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

  Place of processing: Italy – Privacy Policy.

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

• Handling activities related to productivity

  This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
  These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

  Gmail (Google Ireland Limited)

  Gmail is a service that manages email communication provided by Google Ireland Limited. 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: city; country; Data communicated while using the service; date of birth; email address; first name; last name; password; phone number; physical address; profile picture; Usage Data; username.

  Place of processing: 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.

  Google Sheets (Google Ireland Limited)

  Google Sheets is an online spreadsheet and collaboration service provided by Google Ireland Limited.

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

  Place of processing: Ireland – Privacy Policy.

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

• Handling payments

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

  Payment by bank transfer (this Website)

  In the event that the chosen payment method is a direct bank transfer to the current account indicated by this Website, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.

  Personal Data processed: first name; last name; payment info; physical address.

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

  Stripe (Stripe Payments Europe, Limited)

  Stripe is a payment service provided by Stripe Payments Europe, Limited.

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

  Place of processing: European Union – Privacy Policy.

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

  Recurly (Recurly, Inc.)

  Recurly is a payment service provided by Recurly, Inc.

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

  Place of processing: United States – Privacy Policy.

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

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.

  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.

  SiteGround Hosting (SiteGround Spain S.L.)

  SiteGround Hosting is a hosting service provided by SiteGround Spain S.L.

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

  Place of processing: Netherlands – Privacy Policy.

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

  This processing constitutes:

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  GetResponse widget (Implix Sp. z o.o.)

  The GetResponse widget is a service for interacting with the GetResponse email address management and message sending service provided by Implix Sp. z o.o.

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

  Place of processing: Poland – 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

  Mailchimp widget (Intuit Inc.)

  The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by Intuit Inc.

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

  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

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘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.

  WhatsApp Business Chat widget (Meta Platforms Ireland Limited)

  WhatsApp Business Chat widget is a service for interacting with the WhatsApp instant messaging app and platform provided by Meta Platforms Ireland Limited.

  Personal Data processed: answers to questions; contents of the email or message; Data communicated while using the service; date of the message; first name; last name; phone number; profile picture; sender of the message; time the message was sent; user content.

  Place of processing: 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; inferences drawn from other personal information.

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Location-based interactions

  Non-continuous geolocation (this Website)

  This Website may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

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

  This processing constitutes:

  • a Sharing in California

  Geolocation (this Website)

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

  Personal Data processed: coarse location; geographic position; precise location.

  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
  • 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

• 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.

  GetResponse (Implix Sp. z o.o.)

  GetResponse is an email address management and message sending service provided by Implix Sp. z o.o.

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

  Place of processing: Poland – 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

  Mailchimp (Intuit Inc.)

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

  Personal Data processed: country; email address; first name; last name; phone number; physical address; Trackers; Usage Data; username; various types of Data.

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

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

  Constant Contact (Constant Contact, Inc.)

  Constant Contact is an email address management and message sending service provided by Constant Contact, Inc.

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

  Place of processing: United States – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

  Trustpilot Automatic Feedback Service (Trustpilot A/S)

  The Trustpilot Automatic Feedback Service is a message-sending service provided by Trustpilot A/S that automates the sending of email requests for product or service reviews based on specific Users’ actions performed on this Website.

  Personal Data processed: billing address; city; contents of the email or message; country; county; email address; first name; invoicing information; IP address; last name; order ID; payment info; phone number; province; purchase history; state; Trackers; Usage Data; ZIP/Postal code.

  Place of processing: Denmark – Privacy Policy.

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

• Managing data collection and online surveys

  This type of service allows this Website to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

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

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

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

  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 this Website 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).

  Mailchimp Inbox (Intuit Inc.)

  Mailchimp Inbox is a support and feedback management service provided by Intuit Inc.

  Personal Data processed: email address; Usage Data; user content.

  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

  WhatsApp Business customer support (Meta Platforms Ireland Limited)

  WhatsApp Business customer support is a customer support service provided by Meta Platforms Ireland Limited.

  Personal Data processed: answers to questions; app information; billing address; browser information; browsing history; city; contents of the email or message; country; county; custom events; customer support; Data communicated while using the service; date of the message; device information; device logs; first name; geography/region; in-app messages ; interaction events; invoicing information; IP address; language; last name; latitude (of city); login history; longitude (of city); metro area; operating systems; order ID; phone number; primary account information; product interaction; profile picture; province; purchase history; sender of the message; state; time the message was sent; time zone; Trackers; Usage Data; user content; username; ZIP/Postal code.

  Place of processing: Ireland – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California
  • a Sharing in California

• Platform services and hosting

  These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
  Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  WordPress.com (Automattic Inc.)

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

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

  ClickFunnels (Etison, LLC)

  ClickFunnels is a platform provided by Etison, LLC that allows the Owner to build, run and host this Website.

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

  Place of processing: United States – Privacy Policy.

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

• Registration and authentication

  By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website 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.

  Gmail permissions to access User Data (OAuth addition) (Google Ireland Limited)

  To provide its service, this Website uses restricted scopes for Gmail which allow access to User Data related to this Google service (as indicated below). This access is provided by Google Ireland Limited under strict terms. Here's what this means for such User Data:

  • The use of User Data is limited to providing or improving User-facing features. User Data will not be used for serving ads, including retargeting, personalized, or interest-based advertising.
  • User Data will be transferred to third parties only if necessary, to provide or improve User-facing features and as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to Users.
  • Humans will not read the Data unless:
    • the Owner has obtained the User's affirmative agreement for specific messages;
    • it is necessary for security purposes and/or to comply with applicable law, or;
    • the use is limited to internal operations and the Data (including derivations) have been aggregated and anonymized.

  Personal Data processed: Basic settings management; Compose; Full access; Insert and import; Modify; Read metadata; Read only access; Sensitive settings management.

  Place of processing: Ireland – Privacy Policy.

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

  This processing constitutes:

  • a Sale in California

  Direct registration and profiling (this Website)

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

  Personal Data processed: billing address; county; date of birth; email address; first name; gender; geographic position; house number; last name; phone number; physical address; Tax ID; Trackers; Usage Data; various types of Data; ZIP/Postal code.

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

• Registration and authentication provided directly by this Website

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

  Direct registration (this Website)

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

  Personal Data processed: country; county; email address; first name; last name; Trackers; User ID; various types of Data.

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

  This processing constitutes:

• Remarketing and behavioral targeting

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

  Meta Custom Audience (Meta Platforms Ireland Limited)

  Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Website with the Meta Audience Network.

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

  Personal Data processed: email address; Trackers.

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

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

• SPAM protection

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

  Akismet (Automattic Inc.)

  Akismet is a SPAM protection service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing.

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

  This processing constitutes:

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

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

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

  Place of processing: Ireland – Privacy Policy.

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

  Cloudflare Bot Management (Cloudflare, Inc.)

  Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.

  Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.

  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; inferences drawn from other personal information.

  This processing constitutes:

  • a Sharing in California

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on this Website 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: 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

• Traffic optimization and distribution

  This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website 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.

  Bunny CDN (BunnyWay d.o.o.)

  Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.

  Personal Data processed: Usage Data.

  Place of processing: Slovenia – 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

  Cloudflare (Cloudflare, Inc.)

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

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

  Place of processing: United States – Privacy Policy.

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

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

• Personal Data collected through sources other than the User

  The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

• 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 this Website, 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.

• 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. This Website 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. This Website 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 this Website, 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 this Website 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.

• Preference Cookies

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

• Unique device identification

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

• Selling goods and services online

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

Cookie Policy

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

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The rights of Users according to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following:

• right of access to Personal Data;
• right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
• right to receive their Personal Data and have it transferred to another controller (data portability);
• right to ask for incorrect Personal Data to be corrected.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

Further information for Users in Brazil

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

The grounds on which we process your personal information

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

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

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

Categories of personal information processed

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

Why we process your personal information

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

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

Your Brazilian privacy rights

You have the right to:

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

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

How to file your request

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

How and when we will respond to your request

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

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

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

Transfer of personal information outside of Brazil permitted by the law

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

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

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website 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 this Website.

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

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

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

How and when we are expected to handle your request

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

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

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

Additional information for Users in the United States

Collection of personal information about California consumers aged 13 to 16

We collect personal information of consumers between the age of 13 and 16 and won't sell or share their data personal information unless those consumers have opted in.

We do not collect personal information about California consumers below the age of 16

We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.

Additional information about Data collection and processing

Legal action

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

Additional information about User's Personal Data

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

System logs and maintenance

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

Information not contained in this policy

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

Changes to this privacy policy

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

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