Owner and Data Controller
Neighborly Interactive / Save On Cannabis -1887 Whitney Mesa Dr. #8277, Henderson, Nevada 89014 USA
Owner contact email: hello@saveoncannabis.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies; Usage Data; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; language; first name; last name; phone number; country; city; address; state; company name; device information; Invoicing information; Data communicated while using the service; payment info; Data communicated in order to use the Service; session duration; scroll-to-page interactions; clicks; time zone; mouse movements; interaction events; diagnostic events; page events; custom events; layout details; positional information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Displaying content from external platforms, Heat mapping and session recording, Managing contacts and sending messages, SPAM protection, Access to third-party accounts, Contacting the User, Interaction with external social networks and platforms, Registration and authentication, Location-based interactions, Platform services and hosting, User database management, Infrastructure monitoring, Tag Management, Hosting and backend infrastructure, Traffic optimization and distribution, Managing support and contact requests, Advertising and Handling payments.
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:
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Access to third-party accounts
This type of service allows this Application 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 this Application to connect with the User's account on the Twitter social network, provided by Twitter, 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:
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a sale according to the CCPA, CPA, CTDPA and UCPA
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers 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 Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google AdSense (Google LLC)
Google AdSense is an advertising service provided by Google LLC. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
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.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
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: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Wordpress Stats (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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 Application 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:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: email address; first name; last name.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.
Personal Data processed: email address; 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:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
YouTube IFrame Player (Google LLC)
YouTube IFrame Player is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Video Vimeo (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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Handling payments
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Square (Square, Inc.)
Square is a payment service provided by Square, Inc.
Personal Data processed: email address; first name; last name; payment info; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Coinbase (Coinbase Inc.)
Coinbase is a payment service provided by Coinbase, Inc.
Personal Data processed: email address; payment info; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. 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: Cookies; 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:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Big Scoots Hosting
BigScoots Privacy Policy
BigScoots.com (“BigScoots”) has developed this privacy statement to validate our commitment to confidentiality to all our customers and users who use BigScoots’ online services (“Services”). These services consist of domain purchase, transfer and management, shared web hosting, reseller web hosting, managed wordpress hosting, virtual private servers, hybrid servers, data backups, dedicated servers and colocation.
This privacy policy dictates the methods in which BigScoots preserves, maintains and divulges information gathered from its clients and the steps we take to conform to the E.U.-U.S. Privacy Shield Program.
1. Our Commitment to Privacy
BigScoots is committed to crafting long lasting relationships based on trust and transparency. All of us at BigScoots always has and always will do anything reasonably within our power to ensure your right to privacy is preserved. Our services are not directed at anyone under the age of thirteen.
2. Data We Collect
On occasion BigScoots requests and gathers personal information from our clients in a variety of ways. These consist of online data entry forms for ordering products and services, communicating with the BigScoots staff, as well as other instances where users can volunteer their own private information.
The data we gather is undeniably personal and can be used to identify you, which is exactly why we take privacy so seriously and also why it is a necessary evil. Personal information plays a commanding role when conducting business online in a secure manner.
Some of the data gathered can consist but is not limited to:
Complete address and location
Personal and company web addresses
Given name and surname
E-mail addresses
Telephone numbers
Credit card information
Other billing information
Although rare, on occasion BigScoots may gather data about how our clients access our services using tracking identifiers which are specific to each client through the use of cookies or other similar means.
3. What Exactly Are Cookies
A cookie can be fundamentally defined as a piece of data that is stored on a clients computer which identifies information about that specific client. BigScoots on occasion can make use of both session identifier cookies as well as persistent cookies. With session identifier cookies once the browser is closed or logged out of, the cookie is automatically erased. A persistent cookie on the other hand is a minor text file that is stored on your hard drive for a prolonged period of time.
By using our services you are agreeing to the overall acceptance of this privacy policy and therefore our use of cookies. At any time feel free to review your browsers help file to gather the instructions necessary to remove these persistent cookies, however please keep in mind they are only being used in the first place to stream line our interaction with you and better our service.
4. Log Files
Similar to most websites out there, BigScoots uses log files for both security and to streamline our services. This is a form of data gathering which may include information such as internet protocol addresses, internet service providers, browser type and versions, referring and exit pages, platforms, date and time stamps, number of clicks for trend analysing as well as gathering very broad demographic information. Similar to the cookie scenario none of the information stored in these log files contain individually distinguishable data.
5. How Does BigScoots Use This Information?
BigScoots may use any of the individually distinguishable data gathered by BigScoots to contact our clients concerning services offered by BigScoots, and to the extent the client has agreed, by trusted business partners, affiliates or independent contractors.
BigScoots may also use any of the gathered data for analysis on the success of our services and advertising efforts. Under no condition other than legal action or our client specifically authorizing such disclosures will BigScoots ever share this information with a third party.
6. Disclosure of Data
Although unlikely and not in the foreseeable future, BigScoots does reserve the right to disclose completely anonymous data to investors and/or possible partners. In this case purely basic information will be disclosed and individually distinguishable data will remain completely private. In the case of BigScoots being sold, the information collected from our clients may be transferred to the new owner(s) under the condition that all individually distinguishable data will remain private.
BigScoots may on occasion interact with a third party consultant, advisor, marketing team or IT professional where it may become necessary to disclose private data. Everything disclosed under these terms will require the third party to treat all data, especially individually distinguishable data with the same concern and respect that BigScoots does. All third parties are prohibited from disclosing such data to any other person or party.
Further, individuals will always have access to their own personal data unless those same individuals have previously requested their data to be removed.
In the context of an onward transfer, BigScoots has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. BigScoots shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless BigScoots proves that it is not responsible for the event giving rise to the damage.
7. Newsletters, Special Offers And Service Updates
On occasion and on no particular schedule our clients may receive details on special offers, general newsletters as well as service updates providing they have agreed to receive this type of communication.
8. Legal Disclaimer
Although BigScoots takes every precaution to maintain your confidentiality, on occasion a need may arise where we can and should disclose personally identifiable information if required by law. These disclosures will only occur if BigScoots has a good-faith belief that such action is necessary or BigScoots is required to comply with a current judicial proceeding, a court order or legal process served to BigScoots.
On occasion our clients may also find links to other websites through the BigScoots site or through other correspondence. It is our clients responsibility to be aware that BigScoots cannot control the privacy policies of third parties. Read the privacy policies of websites that collect personally identifiable data thoroughly and be aware of how it can be distributed. This privacy policy as indicated herein is applicable only to the data collected by BigScoots.
9. Data Upkeep
The majority of the data gathered by BigScoots is saved indefinitely and for security and data preservation reasons may be saved on more than one database that may be directly or indirectly supported by BigScoots.
Though impossible to absolutely guarantee that misuse, abuse, adjustment or loss to the data will not occur over time, BigScoots makes every possible effort within reason to avert such incidences.
10. Your Responsibility
As with any personal account information you alongside the rest of our clientele are responsible for maintaining the integrity of the login information you are given. This information can consist of but is not limited to user-names and passwords that give access to personal and private information. A valuable life lesson many of us learn far too late; keep your login information safe and never share it with others. Under no circumstance will BigScoots or any of its employees ask for your login credentials.
It is your personal responsibly while maintaining your data security here at BigScoots to educate yourself on mischievous software and potential scams. Key loggers, viruses and a collection of other scams can seize your information from where you access your BigScoots services. For this reason it is necessary to understand your own risks from personal devices and maintain a high level of security awareness. Additionally, when accessing BigScoots services from foreign devices you should take further precautions and always remember to log out when you are done.
11. Questions, Concerns And Comments
As with any of our policies and services we offer here at BigScoots we are always looking for ways to improve. If there are any questions, concerns or comments please feel free to contact us and let us know what we can do to make your BigScoots experience even better.
Although BigScoots makes a conscious effort to keep our clients in the loop on any changes to this Privacy Policy, it is possible that it can be changed without notice. It is your responsibility to review the policy regularly and communicate any discrepancies you may find.
12. Privacy Shield
BigScoots complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. BigScoots has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
In compliance with the EU-US Privacy Shield Principles, BigScoots commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact BigScoots at:
BigScoots, INC.
877-570-3396
abuse@bigscoots.com
BigScoots has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, a panel established by the EU data protection authorities (DPAs).
Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
If your complaint is not satisfactorily addressed, you should contact the state or national data protection or labor authority in the jurisdiction where you work. BigScoots agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel.
BigScoots’s Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Under the Privacy Shield Principles, individuals have the right to opt out of (i) disclosures of their personal information to third parties; or (ii) uses of their personal information
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
FreshPing
Effective Date
October 1, 2019
For prior version, please click here.
Freshworks, Inc and its group companies (collectively “Freshworks”, "we", "us", and "ours") is committed to protecting your privacy. This Privacy Notice (“Notice”) describes how Freshworks processes Personal Data in its capacity as a controller (i.e. Freshworks decides what Personal Data is collected and what it is used for) or processor (i.e. Freshworks only processes the data as per the controller's instructions), as the case may be. It also describes your choices regarding use, access and correction of your Personal Data.
QUICK LINKS
We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.
Definitions
Whom does this Notice Apply to?
Any Questions?
What Personal Data does Freshworks collect and why?
Personal Data we collect and process for our own purposes: Collected Data
What is our legal basis for processing Personal Data (EEA and Swiss visitors only)?
Data we process on your behalf: Service Data
Single Sign-On
Social Media Features
Sharing of Personal Data
Information that we obtain from third parties
Privacy Shield Compliance
How does Freshworks keep Personal Data secure?
EEA and Swiss Specific Rights
Other Communications
Retention of Personal Data
Link to Third Party Sites
Children’s Personal Data
Amendments
Legal Disclosure
Contacting Freshworks
DEFINITIONS
The capitalized terms used in this Notice but not defined herein shall have the same meaning as defined in the Terms of Service at https://freshworks.com/terms/(“Terms”).
WHOM DOES THIS NOTICE APPLY TO?
This Notice applies to (i) entities or individuals, excluding End-Users and Users, who have subscribed to our Service(s) and have agreed to the Terms (hereinafter referred to as the “Customer”) and (ii) individuals (“Individuals”) from whom Freshworks collects data as a controller as specified below.
ANY QUESTIONS?
If you have questions or complaints regarding our privacy notice or practices, please contact us at support@freshworks.com.
WHAT PERSONAL DATA DOES FRESHWORKS COLLECT AND WHY?
A) Personal Data we collect and process for our own purposes: Collected Data
When you visit our Websites or participate in Freshworks’s events, Freshworks may collect information, which may include Personal Data, from Individuals as set forth below (collectively referred to as “Collected Data”). For the purposes of General Data Protection Regulation (GDPR), Freshworks shall be the controller for the Collected Data – this means that Freshworks decides what Collected Data is processed and why.
When does Freshworks process Collected Data?
1) Sign-up, billing and Account information.
When you subscribe and sign-up to any of our Service(s), we may collect your (i) contact information such as name, e-mail address, mailing address, IP address, geographic location, or phone number of the Account admin; (ii) billing information, such as credit card number and billing address; (iii) name and e-mail address when Account admin/Agent(s) provide feedback from within the Service(s); and (iv) unique identifiers, such as username, account number or password.
Subject to this Notice and the Terms, we will use such data, including without limitation, to (i) provide you the Service(s); (ii) send you communication from the Service(s); (iii) assess needs of your business to determine or suggest suitable Service(s); (iv) send you requested information about the Service(s); (v) respond to customer service requests, questions and concerns; (vi) administer your Account; (vii) send you promotional and marketing communications (where you have requested us to do so); and (viii) facilitate your transactions with other users when you use our Service(s).
2) Freshworks Careers.
When you apply for an open position by populating the application form, we may collect your (i) contact information, such as name, email address, mailing address, phone number, links to your social networking profiles; and (ii) any other information contained in the resume that you submit to us.
Subject to this Notice, we will use such data to evaluate you for the open position that you have applied for or any position that we consider you suitable for at the time you submit your resume or at any later date. Unless you notify us otherwise by an e-mail to support@freshteam.com, we will retain such data for a period of 1 year for archival purposes. If you wish to update the data you provided to us, you may do so by contacting us at support@freshteam.com.
For the purposes of evaluating you for an open position, you understand that we may internally rate you based on parsing of your resume and your information. If you do not wish to be rated by us, please do not provide us your information.
3) Events.
When you attend an event conducted by Freshworks, including webinars or seminars, we may collect your contact information such as name, e-mail address, designation and company name.
Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.
4) Referrals via Glowboard.
To help refer our Service, Customers can provide us with contacts within the Service. We may collect contact information such as name, e-mail address, mailing address, or phone number of such contact from our Customer. By providing us this information about third parties, you warrant you have complied with all necessary legal requirements to provide us with this information, including obtaining all necessary consents and providing the third party with a copy of this Notice.
If you have been referred by our Customer, then, subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you promotional and marketing communications (where you have requested us to do so); and (iii) respond to your questions and concerns.
5) Program Registrations.
When you register for any of our programs through a registration form on our Websites, we may collect information such as name, e-mail address, company name and website URL, company details, location and contact information. Subject to this Notice, we will use such data, including without limitation, to (i) facilitate your use of the program portal for which you have registered; (ii) send you communication from within the Service(s); (iii) send you requested information about our Service(s); (iv) respond to your requests, questions and concerns; and (v) send you promotional and marketing communications (where you have requested us to do so).
6) Public forums, Forms and Newsletters.
When you visit our publicly accessible community forums and blogs or submit any forms on our Website, you should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Further, we may collect your (i) contact information such as name, e-mail address, mailing address, or phone number; (ii) information about your business, such as company name, company size, business type; and (iii) a short bio about you to identify you as the author of the post. When you actively subscribe to our newsletters, we collect your e-mail address to share our newsletters with you.
Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so); and (iv) respond to your questions and concerns.
7) Cookies and Similar Technologies.
We and our third party advertising partners use cookies and similar technologies in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Most web browsers support cookies and users can control the use of cookies at the individual browser level. Please note that if you choose to disable cookies, it may limit your use of certain features or functions on our Websites and services.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Website (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other data we collect about you. We do this mainly to improve services We offer you, to improve marketing, analytics, and/or Website performance and functionality.
Please see our Cookies Policy for further information about our use of Cookies and similar technologies.
8) Analytics.
Apart from the aforementioned information collected by us, we automatically receive and record certain Personal Data of yours when You visit our Websites. This includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs. We also collect clicks, scrolls, conversion and drop-off on our Websites and Service(s) to render user journey at real-time. Subject to this Notice, we will use such data, including without limitation, to (i) assess needs of your business to determine or suggest suitable Service(s); (ii) send you requested information about the Service(s); (iii) respond to customer service requests, questions and concerns; and (iv) for analytical purposes.
You authorize Freshworks and its service providers to perform analytics on such Collected Data, to (i) improve, enhance, support and operate the Websites; and (ii) compile statistical reports and record insights into usage patterns. You acknowledge that Freshworks uses Collected Data, as the case may be, for the aforementioned purposes.
9) Testimonials.
We may post your testimonials/comments/reviews on our Websites which may contain your Personal Data. Prior to posting the testimonial, we will obtain your consent to post your name along with the testimonial. If you want your testimonial removed, please contact us at support@freshworks.com.
You understand that we will not be liable to any person for unauthorized publishing of testimonials by customers of Glowboard. If you, as a Customer of our Service Glowboard, wish to publish on your websites, any testimonials you have received from third parties via e-mails or widgets, it is your responsibility to obtain consent from such third parties prior to publishing the testimonials.
10) Marketing communications.
When you have agreed to, we may use your e-mail address, collected as part of Collected Data, to send our newsletters and/or marketing communications about our products and services. Where you have so requested, we will also send you marketing communications about our third party partners. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the e-mails you receive or by contacting us at support@freshworks.com.
What is our legal basis for processing Personal Data (EEA and Swiss visitors only)?
If you are a visitor from the European Economic Area or Switzerland, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
However, we will normally collect Personal Data from you only where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.
B) Data we process on your behalf: Service Data
We only process Service Data as per our Customer's instructions. For purposes of the GDPR and the Swiss Federal Act on Data Protection, we are the processor and not the controller of the Service Data. Service Data, as defined in the Terms, means all electronic data, text, messages or other materials, including Personal Data of Users and End-Users, submitted to the Service(s) by our Customers through Customer’s Account in connection with Customer’s use of the Service(s), including data collected under “Other Information” and “Mobile Applications” below. Our EEA or Switzerland based Customers are the “controllers” of that data and are responsible for compliance with the applicable data protection law. We work with our Customers to help them provide notice to their customers concerning the purpose for which Personal Data is processed by Freshworks.
If you are our Customer from EEA or Switzerland, then in your role as a controller, you are authorizing, on behalf of you and your authorized agents and End-Users, and representing that you have the authority to provide such authorization to the processing and transfer of Personal Data in and to the United States and other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that the Service Data is treated securely and in accordance with this Notice.
We do not own, control or direct the use of Service Data, and in fact we are largely unaware of what information is being stored on our platform and only access such information as reasonably necessary to provide the Service(s) (including to respond to support requests), as otherwise authorized by Customers or as required by law. Unless we explicitly agree otherwise in writing, you will not process sensitive personal data (such as health data) on our platform.
As the controller, it shall be your responsibility to inform the End-Users about the processing, and, where required, obtain necessary consent or authorization for any Personal Data that is collected as part of the Service Data through your use of the Service(s). As the processors of Personal Data on behalf of our Customers, we follow Customer’s instructions with respect to the Service Data to the extent consistent with the functionality of our Service(s). In doing so, we implement technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, Personal Data.
Other Information.
Where an User or End-User uses the Service(s), we automatically receive and record certain information of such user. This information includes device model, IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs (collectively referred to as “Other Information”). If you are a customer of Freshchat, please note that you will have the option to opt out of tracking certain events from within Freshchat.
Mobile Applications.
When you download, install and use our Mobile Applications, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”).
We use mobile analytics software to allow Us to better understand the functionality of our Mobile Software on your phone. This Software may record certain information such as how often you use the application, the events that occure within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the Mobile Applications.
Subject to this Notice, we will use such data to (i) provide and manage Mobile Application; (ii) if you have opted in to receiving push notifications, send you push notifications from time-to-time in order to update you about any events or promotions that we may be running and/or update you about new features to our Service(s); (iii) send you promotional and marketing communications (where you have requested us to do so). If you no longer wish to receive these types of communications, you may turn them off at the device level.
Improving and enhancing our Service(s).
You expressly authorize us and the service providers we use to process the Service Data in our systems to (i) provide, improve, enhance, support and operate the Service(s) and its availability; (ii) develop new products and services; and (iii) compile statistical reports and record insights into usage patterns.
SINGLE SIGN-ON
You can log in to our Websites using sign-in services such as Google, Facebook Connect and LinkedIn. These services will authenticate your identity and provide you the option to share certain Personal Data with us such as your name and e-mail address. Services like Google, Facebook Connect, Twitter, LinkedIn give you the option to post information about your activities on our Websites to your profile page and to share information with others within your network.
SOCIAL MEDIA FEATURES
Our Websites includes social media features, such as the Facebook “Like” button, the “Share This” button or interactive mini-programs. Where you interact with these features, they may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy notice of the company providing them. Please see our Cookies Policy for further information.
SHARING OF PERSONAL DATA
We process Personal Data in the United States and the European Economic Area (“EEA”) and in other countries through third parties that we may use. You may refer to the page here for more information on hosting options.
We may also share your Personal Data as follows:
With third party assisting Freshworks in providing you the Service(s) (“Sub-Processors" listed here). Our Sub-Processors are given access to Customer’s Account and Service Data only as reasonably necessary to provide the Service(s) and will be subject to confidentiality obligations in their service agreements;
With third party service providers providing services, such as research and analytics, marketing and data enrichment or for them to reach out to you on our behalf;
With third-party payment processors who process your credit card and other payment information for Freshworks but are otherwise not permitted to store, retain or use such information;
With third party partners for the purpose of assisting us in onboarding you and providing any further support needed to use our Service(s);
With sponsors of contests for which you register;
With third-party social media networks, advertising networks and websites;
With affiliates within Freshworks and companies that we will acquire in the future when they are made part of the Freshworks group for customer support, marketing, technical operations, account management or organizational purposes and to provide, enhance and improve the Service(s);
If we are involved in a merger, reorganization or other fundamental corporate change with a third party, or sell/buy a business unit to/from a third party, or if all or a portion of our business, assets or stock are acquired by a third party, with such third party including at the due diligence stage. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to unaffiliated third party.
All such transfers are covered by the service agreements with the relevant recipients and we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Privacy Notice. Further details can be provided upon request.
INFORMATION THAT WE OBTAIN FROM THIRD PARTIES
From time to time, we may receive personal information about you from third party sources like databases and social media but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we obtain from such third parties include your name, e-mail address, postal address, location, designation, telephone number and we use the information we receive from these third parties to maintain and improve customer support experience, improve the accuracy of the records we hold about you and for our sales and marketing purposes.
TRUSTe
Privacy Shield Compliance
Freshworks, Inc. participates in and has certified its compliance with the EU-U.S. and Swiss-US Privacy Shield Framework. Freshworks, Inc. is committed to subjecting all Personal Data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List [https://www.privacyshield.gov/list]. Freshworks, Inc. complies with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and United Kingdom and/or Switzerland, as applicable, to the United States in reliance on Privacy Shield. Freshworks, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Freshworks, Inc. is responsible for the Personal Data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Freshworks, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, and Switzerland including the onward transfer liability provisions. Freshworks further commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, Freshworks, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Freshworks, Inc. and/or its Group Companies may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
HOW DOES FRESHWORKS KEEP PERSONAL DATA SECURE?
We use appropriate technical and organizational measures to protect the Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.
While information security risks are always evolving, so are the controls. The controls, so implemented, are periodically reviewed as part of internal and external audits. If you have questions about the security of your Personal Data, please contact us immediately as described in this Privacy Notice.
EEA AND SWISS SPECIFIC RIGHTS
A) Collected Data
If you are an individual resident in EEA or Switzerland, you have the following data protection rights regarding Collected Data:
If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us.
You can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at support@freshworks.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.
B) Service Data
We acknowledge that you have the right to access your Personal Data. Freshworks has no direct relationship with the individuals whose Personal Data it processes. If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which is part of the Service Data and processed by us on behalf of our Customer or if you are an End-User of one of our Customers and would no longer like to be contacted by one of our Customers that uses our Service(s), you should direct your query to our Customer i.e, the controller. if requested to remove data, We will respond within a reasonable timeframe.
If you are a Customer of our Service(s) and wish to raise a Request on behalf of your Users and End-Users in connection with Service Data, you may raise a ticket on the support portal of the relevant Service. Please note that if a Customer has subscribed to more than one Service, a Request on a particular Service support portal is specific to that Service only and separate Requests need to be raised across other relevant Service support portals.
OTHER COMMUNICATIONS
If you are our Customer, we will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an e-mail. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.
RETENTION OF PERSONAL DATA
If you wish to request that we no longer use your Collected Data, please contact us at support@freshworks.com.
Personal Data contained in the Service Data is retained and deleted in accordance with the Terms.
Notwithstanding the foregoing, we will retain Collected Data and Service Data as necessary to comply with our legal obligations, for litigation/defense purposes, maintain accurate financial and other records, resolve disputes, and enforce our agreements.
LINKS TO THIRD PARTY SITES
Our Websites contain links to other websites that are not owned or controlled by Freshworks. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Websites and to read the privacy policies of each and every website that collects Personal Data.
CHILDREN'S PERSONAL DATA
Freshworks does not knowingly collect any Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Notice by instructing their children never to provide Personal Data through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through our Websites or Service(s), please contact us and we will endeavor to delete that information and terminate the child's account from our databases.
AMENDMENTS
Amendments to this Notice will be posted to this URL and will be effective when posted. If we make any material changes, we will notify you by means of a notice on this Website prior to the change becoming effective and if you are our Customer, via e-mail (specified in your Account). Provided we will not be notifying you if we amend the Notice to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate. You should frequently visit this Notice to check for amendments. Your continued use of our Websites or the Service(s) following the posting of any amendment, modification, or change to this Notice shall constitute your acceptance of the amendments to this Notice. You can choose to discontinue use of the Websites or Service(s), if you do not accept the terms of this Notice, or any modified version of this Notice.
LEGAL DISCLOSURE
We, including our Group Companies reserve the right to disclose your personal data contained in Collected Data and Service Data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Collected Data and Service Data will also be shared between our Group Companies for the activities permitted under the Terms and this Notice.
In the event Freshworks goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, Customer’s Account, Collected Data and Service Data will likely be among the assets transferred. A prominent notice will be displayed on our Websites to intimate you of any such change in ownership or control and Customers will be notified via an e-mail from support@freshworks.com.
CONTACTING FRESHWORKS
If you have any questions about this privacy notice or your dealings with the Freshworks, you can contact us at dpo@freshworks.com or support@freshworks.com or via postal mail at Freshworks, Inc., 2950 S.Delaware Street, Suite 201, San Mateo, CA 94403 for the attention of the Data Protection Officer with a CC to legal@freshworks.com.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA and VCDPA
Coinbase button and widgets (Coinbase Inc.)
The Coinbase button and widgets are services allowing interaction with the Coinbase platform provided by Coinbase Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Location-based interactions
Non-continuous geolocation (this Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
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 sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Managing 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.
OneSignal (Lilomi, Inc.)
OneSignal is a message sending service provided by Lilomi, Inc.
OneSignal 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.
Depending on the permissions granted to this Application, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User's device. This Application uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.
The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal's use of Data, consult OneSignal's privacy policy.
Push notifications opt-out
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.
Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones.
Different device configurations, or updates to devices, may affect or change how these indicated settings work.
Personal Data processed: Cookies; email address; geographic position; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
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 sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data processed: email address; 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
ZOHO Campaigns (Zoho Corporation Pvt. Ltd.)
ZOHO Campaigns is an email address management and message sending service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: city; country; email address; first name.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
ZOHO CRM Email (Zoho Corporation Pvt. Ltd.)
ZOHO CRM Email is a support and contact request management service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: company name; country; Data communicated while using the service; email address; first name; Invoicing information; last name; phone number; physical 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; commercial information; internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application.
Personal Data processed: 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 according to the CCPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. 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.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA and VCDPA
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
WordPress.com Single Sign On (Automattic Inc.)
WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and is connected to the WordPress.com 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed: email address; first name; last name.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic 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 according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
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 according to the CCPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.
Personal Data processed: Cookies; 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
-
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
HubSpot Lead Management (HubSpot, Inc.)
HubSpot Lead Management is a User database management service provided by HubSpot, 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
ZOHO CRM (Zoho Corporation Pvt. Ltd.)
ZOHO CRM is a User database management service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: address; city; company name; country; email address; first name; last name; phone number; state.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
-
Push notifications
This Application may send push notifications to the User.
-
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 this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
-
Push notifications for direct marketing
This Application 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 this Application).
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 this Application or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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.
-
Push notifications based on the User's geographic location
This Application 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 this Application.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), 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, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for California consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).
Notice at collection
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information, internet or other electronic network activity information, geolocation data and inferences drawn from other personal information.
We have collected the following categories of sensitive personal information: payment info and payment info
We will not collect additional categories of personal information without notifying you.
Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it
You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.
We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.
Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.
To fully exercise your right to limit the use or disclosure of your sensitive personal information you can contact us at any time, using the contact details provided in this document.
For a simplified method you can also use the privacy choices link provided on this Application.
We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.
Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CTDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the UCPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.