Privacy Policy of conversionengineering.co

Owner and Data Controller

Conversion Engineering, 2147 Rue Chateauguay, Montreal, QC, Canada, H3K 1K7

Owner contact email: ross@conversionengineering.co

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; first name; last name; phone number; company name; email address; username; website; various types of Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); country; city; ZIP/Postal code; Data communicated while using the service; name; calendar information; Universally unique identifier (UUID); device information; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.

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

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

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.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

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.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Interaction with external social networks and platforms, Contacting the User, Tag Management, Backup saving and management, Content commenting, Content performance and features testing (A/B testing), Displaying content from external platforms, Handling payments, Remarketing and behavioral targeting, Social features, User database management, Platform services and hosting, Advertising, Connecting Data, Interaction with data collection platforms and other third parties, Handling activities related to productivity, Managing data collection and online surveys, Interaction with live chat platforms, SPAM protection and Managing support and contact requests.

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

Detailed information on the processing of Personal Data

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

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers 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.

  Direct marketing via SMS (this Application)

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

  Personal Data processed: first name; last name; phone number.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  Google Ad Manager (Google LLC)

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

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

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  Direct Email Marketing (DEM) (this Application)

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

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  Direct Advertising (this Application)

  This Application uses User Data to propose services or products provided by third parties, related or unrelated to the product or service provided by this Application.

  Direct Advertising may involve the use of Trackers to monitor Users’ behavior and serve personalized ads. Users may opt-out of ad personalization by visiting their device settings or following the instructions provided by YourOnlineChoices and AdChoices.

  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.

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

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

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  Facebook Lookalike Audience (Facebook, Inc.)

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

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

  Personal Data processed: Tracker; Usage Data.

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

• Analytics

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

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Analytics with anonymized IP (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.
  This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  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 CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Display Advertising extension for Google Analytics (Google Inc.)

  Google Analytics on this Application might use Google's Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Ads conversion tracking (Google Inc.)

  Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Application.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Wordpress Stats (Automattic Inc.)

  Wordpress Stats is an analytics service provided by Automattic Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Analytics Demographics and Interests reports (Google LLC)

  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: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Attribution (Attribution, LLC)

  Attribution is an analytics service provided by Attribution, LLC.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Backup saving and management

  This type of services allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.

  Backup on Dropbox (Dropbox, Inc.)

  Dropbox is a service to save and manage backups provided by Dropbox Inc.

  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 CPRA (CCPA amendment): internet information.

  Backup on Google Drive (Google LLC)

  Google Drive is a service to save and manage backups provided by Google LLC.

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

• Connecting Data

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

  Zapier (Zapier, Inc.)

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

  Personal Data processed: city; country; Data communicated while using the service; email address; first name; last name; phone number; Tracker; Usage Data; ZIP/Postal code.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CPRA (CCPA amendment)

• Contacting the User

  Contact form (This Application)

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

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information.

  This processing constitutes:

  • a sale according to the VCDPA

  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: company name; email address; first name; last name; phone number.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; commercial information.

  This processing constitutes:

  • a sale according to the VCDPA

• Content commenting

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

  Comment system managed directly (This Application)

  This Application has its own internal content comment system.

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

• 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.

  Google Optimize (Google Inc.)

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

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

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Displaying content from external platforms

  This type of services 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 Inc.)

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

  Personal Data processed: 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 CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Programmable Search Engine (Google Inc.)

  Google Programmable Search Engine is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Gravatar (Automattic Inc.)

  Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
  Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.

  Personal Data processed: email address; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Wistia widget (Wistia, Inc.)

  Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  YouTube video widget (Google Inc.)

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

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Wistia widget (Privacy Mode) (Wistia, Inc.)

  Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate content of this kind on its pages.

  This widget is set up in a way that ensures that Wistia only collects fully anonymized viewing data about Users on this Application unless they opt in to being tracked.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Handling activities related to productivity

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

  Calendly (Calendly, LLC)

  Calendly is a service provided by Calendly, LLC, that facilitates online scheduling of appointments.

  Personal Data processed: calendar information; email address; name; phone number.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  Google Docs (Google LLC)

  Google Docs is an online text-editing and collaboration service provided by Google LLC.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the CPRA (CCPA amendment)

  Google Sheets (Google LLC)

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

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the CPRA (CCPA amendment)

  Trello (Trello, Inc. )

  Trello is a project management service provided by Trello, Inc. .

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the CPRA (CCPA amendment)

• Handling payments

  Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  Freshbooks (2NDSITE Inc.)

  Freshbooks is an invoicing and payment service provided by 2NDSITE Inc.

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

  Place of processing: Canada – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  PayPal (PayPal Inc.)

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

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  Stripe (Stripe Inc)

  Stripe is a payment service provided by Stripe Inc.

  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 CPRA (CCPA amendment): internet information.

• Interaction with data collection platforms and other third parties

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

  JotForm widget (JotForm Inc.)

  The JotForm widget is a service for interacting with the JotForm data collection platform provided by JotForm Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
  The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google+ +1 button and social widgets (Google Inc.)

  The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Facebook Messenger Customer Chat (Facebook, Inc.)

  The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Managing data collection and online surveys

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

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

  Facebook lead ads (Facebook, Inc.)

  Facebook lead ads is an advertising and data collection service provided by Facebook, Inc. that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.

  Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.

  Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.

  Personal Data processed: email address; first name.

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

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  JotForm (JotForm Inc.)

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

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Managing support and contact requests

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

  Help Scout (Help Scout Inc. )

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

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Platform services and hosting

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

  WordPress.com (Automattic Inc.)

  WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application.

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

• Remarketing and behavioral targeting

  This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  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.

  Google Ads Remarketing (Google Inc.)

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

  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: US – Privacy Policy – Opt Out.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  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 CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  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 CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

  Remarketing with Google Analytics (Google Inc.)

  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CPRA (CCPA amendment)
  • targeted advertising according to the VCDPA

• Social features

  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 CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the VCDPA

• 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 LLC)

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

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

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information; inferred information.

• Tag Management

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

  Google Tag Manager (Google Inc.)

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

  Personal Data processed: Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal information collected according to the CPRA (CCPA amendment): internet information.

  This processing constitutes:

  • a sale according to the CPRA (CCPA amendment)

• 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.

  ActiveCampaign (ActiveCampaign, Inc.)

  ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

  Personal Data processed: Cookies; email address; 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 CPRA (CCPA amendment): identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

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

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) 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.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

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.

Information for Californian consumers

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

The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions 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/CPRA).

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, commercial information, internet information and inferred information.

We have collected the following categories of sensitive personal information: 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 opt-out 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 CPRA (CCPA amendment).

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 CPRA (CCPA amendment).

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 CPRA (CCPA amendment).
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CPRA (CCPA amendment), 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. 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 CPRA (CCPA amendment). 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 minor 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.

Information for Virginia consumers

This part 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”).

The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions 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, commercial information, internet information and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

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

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
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.

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 relates 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 minor 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.