Privacy Policy of Midoin

Full policy

Owner and Data Controller

Midoin P.C.
18 Levidiou str.
13121 Ilion (Greece)

Owner contact email: midoin@midoin.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; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; phone number; first name; last name; province; state; country; ZIP/Postal code; gender; date of birth; city; address; Contacts permission; Camera permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Phone permission; SMS permission; Storage permission; Social media accounts permission; geographic position; username; User ID; profile picture; various types of Data; Data communicated while using the service.

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.

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: Access to third-party accounts, Advertising, Analytics, Contacting the User, Device permissions for Personal Data access, Hosting and backend infrastructure, Infrastructure monitoring, Location-based interactions, Managing contacts and sending messages, Registration and authentication, Remarketing and behavioral targeting, Social features, Displaying content from external platforms, Platform services and hosting, SPAM protection, Content performance and features testing (A/B testing), Content commenting, Data transfer outside the EU and User database management.

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”.

Facebook permissions asked by this Application

This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Access Friend Lists

Provides access to any friend lists the User created.

Birthday

Provides access to the birthday.

Contact email

Access the User's contact email address.

Email

Provides access to the User's primary email address.

List of Friends

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

Share

Share items on the User's behalf.

Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

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

Approximate location permission (continuous)

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

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Camera permission

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

Contacts permission

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

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

SMS permission

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

Social media accounts permission

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

Storage permission

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

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

  This type of service allows 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.

  Facebook account access (this Application)

  This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: About Me; Access Friend Lists; Birthday; Contact email; Email; List of Friends; Photos; Share.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; california Consumer Records Statute information; internet information; sensorial information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

• 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.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

  This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

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

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

  Category of personal information collected according to the CCPA: identifiers; internet 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

  AdMob (Google Ireland Limited)

  AdMob is an advertising service provided by Google Ireland Limited.
  In order to understand Google's use of Data, consult Google's partner policy.

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

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Google Ad Manager (Google Ireland Limited)

  Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.  

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

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Google Ads Similar audiences (Google Ireland Limited)

  Similar audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
  On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.

  Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.

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

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Google AdSense (Google Ireland Limited)

  Google AdSense is an advertising service provided by Google Ireland Limited. 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: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  Audience Network (Audience Network sp. z o.o.)

  Audience Network is an advertising service provided by Audience Network sp. z o.o.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  AdColony (AdColony, Inc.)

  AdColony is an advertising service provided by AdColony, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Amazon Advertising (Amazon Europe )

  Amazon Advertising is an advertising service provided by Amazon Europe .

  Personal Data processed: Tracker; Usage Data.

  Place of processing: European Union – Privacy Policy – Opt out.

  Category of personal information collected according to the CCPA: internet 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

  Amazon Mobile Ads (Amazon)

  Amazon Mobile Ads is an advertising service provided by Amazon.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  AppLovin (AppLovin Corporation)

  AppLovin is an advertising service provided by AppLovin Corporation.

  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 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

  Appnext (Appnext Ltd.)

  Appnext is an advertising service provided by Appnext Ltd.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Virgin Islands, British – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Chartboost (Chartboost, Inc.)

  Chartboost is an advertising service provided by Chartboost Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Flurry RTB (Yahoo! Inc.)

  Flurry RTB (Flurry Real-Time Bidding) is an advertising service provided by Yahoo! Inc. that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
  This Application is collecting and transmitting Data from the User through the Flurry RTB service to media buyers bidding to purchase its inventory. These buyers may collect and store such Data and use such Data for retargeting or other advertising purposes.
  If the User chooses to opt-out, Flurry will stop tracking Data for the device identified by the provided MAC address and/or device identifier going forward. Flurry will also stop providing ads and/or recommendations to that MAC address and/or device identifier across all publishers.
  In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices.

  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 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

  InMobi (InMobi Pte Ltd)

  InMobi is an advertising service provided by InMobi Pte Ltd.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  ironSource (ironSource Ltd.)

  ironSource is an advertising service provided by ironSource Ltd.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Israel – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  MoPub (MoPub Inc.)

  MoPub is an advertising service provided by MoPub Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Ogury (Ogury Ltd.)

  Ogury is an advertising service provided by Ogury Ltd.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  OpenX (OpenX)

  OpenX is an advertising service provided by OpenX.

  Personal Data processed: Tracker; Usage Data.

  Category of personal information collected according to the CCPA: internet 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

  PubNative (PubNative GmbH)

  PubNative is an advertising service provided by PubNative GmbH.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  Smaato (Smaato, Inc.)

  Smaato is an advertising service provided by Smaato, Inc.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  StartApp (StartApp, Inc.)

  StartApp is an advertising service provided by StartApp, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Tapjoy (Tapjoy, Inc.)

  Tapjoy is an advertising service provided by Tapjoy, Inc.

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

  Unity Ads (Unity Technologies ApS)

  Unity Ads is an advertising service provided by Unity Technologies ApS.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Denmark – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Vungle (Vungle, Inc.)

  Vungle is an advertising service provided by Vungle, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

• 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.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the 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: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Google Analytics (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: US – Privacy Policy – Opt Out.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

  Google Analytics for Firebase (Google Inc.)

  Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
  In order to understand Google's use of Data, consult Google's partner policy.

  Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

  This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

  Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  TestFlight (Apple Inc.)

  TestFlight is an analytics service provided by Apple Inc.

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

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Google Analytics Advertising Reporting Features (Google Ireland Limited)

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

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

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

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

  Category of personal information collected according to the CCPA: identifiers; internet 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 Ads conversion tracking (Google Ireland Limited)

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

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Google Analytics Demographics and Interests reports (Google Ireland Limited)

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).

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

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

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

  Category of personal information collected according to the CCPA: identifiers; internet 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 ID extension for Google Analytics (Google Ireland Limited)

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

  Personal Data processed: Cookies.

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Analytics collected directly (this Application)

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

  Personal Data processed: Cookies; Usage Data.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the VCDPA

• Contacting the User

  Phone contact (this Application)

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

  Personal Data processed: phone number.

  Category of personal information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a sale according to the VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  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: address; city; Cookies; country; date of birth; email address; first name; gender; last name; phone number; province; state; Usage Data; ZIP/Postal code.

  Category of personal information collected according to the CCPA: identifiers; biometric information; internet information.

  This processing constitutes:

  • a sale according to the VCDPA, CPA, CTDPA and UCPA

• Content commenting

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

  Facebook Comments (Facebook, Inc.)

  Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

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

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

  Firebase Remote Config (Google Ireland Limited)

  Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.

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

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)

  If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
  In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
  Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

  Personal Data processed: various types of Data.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Data transfer abroad based on standard contractual clauses (this Application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Data transfer to countries that guarantee European standards (this Application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

  Personal Data processed: various types of Data.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

• Device permissions for Personal Data access

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

  Device permissions for Personal Data access (this Application)

  This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Camera permission; Contacts permission; Phone permission; SMS permission; Social media accounts permission; Storage permission.

  Category of personal information collected according to the CCPA: internet information; geolocation data.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

• Displaying content from external platforms

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

  Google Fonts (Google Ireland Limited)

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

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

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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 Ireland Limited)

  Google Maps is a maps visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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 of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

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

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

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

  Place of processing: United States – Privacy Policy; Canada – Privacy Policy; Brazil – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy; India – Privacy Policy; Australia – Privacy Policy; China – Privacy Policy; Korea, Republic of – Privacy Policy; Japan – Privacy Policy; Singapore – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Cloud Functions (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Cloud Storage (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Hosting (Firebase, Inc.)

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

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

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Realtime Database (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Google Cloud Storage (Google Inc.)

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

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

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Google App Engine (Google Inc.)

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

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

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Cloud Firestore

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

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

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  DigitalOcean (DigitalOcean Inc.)

  DigitalOcean is a hosting service provided by DigitalOcean Inc.

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

  Place of processing: United States – Privacy Policy; Canada – Privacy Policy; United Kingdom – Privacy Policy; Netherlands – Privacy Policy; Germany – Privacy Policy; India – Privacy Policy; Singapore – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Heroku (Salesforce.com, inc.)

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

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

  Place of processing: United States – Privacy Policy; European Union – Privacy Policy; Ireland – Privacy Policy; Germany – Privacy Policy; Australia – Privacy Policy; Japan – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  iubenda Consent Solution (iubenda srl)

  iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.

  Personal Data processed: Data communicated while using the service.

  Place of processing: Italy – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the 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.

  Crashlytics (Google Inc.)

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

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

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; internet information; geolocation data.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Crash Reporting (Google Inc.)

  Firebase Crash Reporting is a monitoring service provided by Google, Inc.

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Performance Monitoring (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the 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.

  Firebase Cloud Messaging (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

  Firebase Notifications (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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

• 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.

  Google Play Store (Google Ireland Limited)

  This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

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

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

  Personal Data processed: Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Apple App Store (Apple Inc.)

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

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

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

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: internet 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.

  Direct registration (this Application)

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

  Personal Data processed: country; email address; first name; last name; phone number; profile picture; User ID; username.

  Category of personal information collected according to the CCPA: identifiers; sensorial information.

  This processing constitutes:

  • a sale according to the CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  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: US – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and VCDPA

  Firebase Authentication (Google Inc.)

  Firebase Authentication is a registration and authentication service provided by Google Inc. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; sensorial 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 OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

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

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

• Remarketing and behavioral targeting

  This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

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

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

  Personal Data processed: Cookies; email address.

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

  Category of personal information collected according to the CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Facebook Remarketing (Facebook, Inc.)

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

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Google Ad Manager Audience Extension (Google Ireland Limited)

  Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Google Ads Remarketing (Google Ireland Limited)

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

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

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

  Remarketing with Google Analytics (Google Ireland Limited)

  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CCPA: internet 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

• Social features

  Firebase Invites (Google Inc.)

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

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

  Place of processing: USA – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Inviting and suggesting friends (this Application)

  This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

  Personal Data processed: various types of Data.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Public profile (this Application)

  Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.

  Personal Data processed: first name; last name; username.

  Category of personal information collected according to the CCPA: identifiers.

  This processing constitutes:

  • a sale according to the VCDPA, CPA, CTDPA and UCPA
  • targeted advertising according to the CPA, CTDPA and UCPA

  Firebase Dynamic Links (Google Ireland Limited)

  Firebase Dynamic Links is a social feature provided by Google Ireland Limited. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.

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

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA, VCDPA, 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.

  Google reCAPTCHA (Google Ireland Limited)

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

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to the CCPA: internet information.

  This processing constitutes:

  • a sale according to the 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.

  Intercom (Intercom Inc.)

  Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within this Application.

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CCPA: identifiers; internet 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 follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

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

Further information about the processing of Personal Data

• Access the address book

  This Application may request access to your address book.

• Push notifications

  This Application may send push notifications to the User.

• Unique device identification

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

• User identification via a universally unique identifier (UUID)

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

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

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

• Automated decision-making

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

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

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

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

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

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

• Privacy Shield participation: data transfers from the EU and Switzerland to the United States

  The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner 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 the Owner’s certification, please visit https://www.privacyshield.gov/welcome (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

  What does this mean for the European User?

  The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

  This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

  The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

  With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

  The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  Dispute resolution under the Privacy Shield

  In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

  In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

  In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

  Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

• 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.

• 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.

• Selling goods and services online

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

Transfer of Personal Data outside of the European Union

Data transfer abroad based on standard contractual clauses

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Data transfer to countries that guarantee European standards

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running 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.

Futher 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

Categories of personal information collected, used, sold, or shared

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, california Consumer Records Statute information, biometric information, internet information, geolocation data and sensorial information.

We have collected the following categories of sensitive personal information: username, username and username

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.

Additional information about California privacy

CCPA: Collection of personal information about consumers aged 13 to 16

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

CCPA: Collection of personal information about consumers below the age of 13

We collect personal information of consumers below the age of 13 and won't sell their data unless their parents or guardians have opted-in on behalf of those minors.

CCPA: Collection of personal information about minors

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

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.

Categories of personal data processed

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, internet information, geolocation data and sensorial 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.

Categories of personal data processed

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, internet information, geolocation data and sensorial 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.

Categories of personal data processed

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, internet information, geolocation data and sensorial 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.

Categories of personal data processed

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, internet information, geolocation data and sensorial 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.

Information not contained in this policy

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

Changes to this privacy policy

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

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