Owner and Data Controller
Hearing Tracker, Inc. PO Box 40702, Austin, TX 78704, USA
Owner contact email: privacy@hearingtracker.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Usage Data; Tracker; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; email address; first name; last name; phone number; geographic position; address; gender; date of birth; country; state; province; picture; city; session duration; scroll-to-page interactions; time zone; device information; interaction events; diagnostic events; page events; custom events; layout details; positional information; number of Users; session statistics; browser information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Displaying content from external platforms, Registration and authentication, SPAM protection, Analytics, Contacting the User, Handling payments, Hosting and backend infrastructure, Location-based interactions, Managing contacts and sending messages, Social features, Heat mapping and session recording and Tag 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”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
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.
User ID extension for Google Analytics (Google Inc.)
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: US – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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 or other electronic network activity information.
This processing constitutes:
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“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.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: browser information; device information; number of Users; session statistics.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
-
Contacting the User
Mailing list or newsletter (This Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: email address; first name; last name.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
Contact form (This Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name; phone number.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
-
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of 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: Tracker; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows 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 CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube video widget (Google Inc.)
YouTube is a video content 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: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
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.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe, Inc., Stripe Payments Europe, Limited, Stripe Payments UK, Ltd, Stripe Brasil Soluções de Pagamento - Instituição de Pagamento Ltda., Stripe Payments Canada, Ltd., Stripe India Private Ltd., Stripe Japan KK, Stripe Payments Malaysia Sdn. Bhd., Stripe Payments Mexico, S. de R.L. de C.V., Stripe New Zealand Limited, Stripe Payments Singapore Pte. Ltd. or by Stripe Payments (Thailand) Ltd., 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 or other electronic network activity information.
This processing constitutes:
-
Heat mapping and session recording
Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
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.
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: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Location-based interactions
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.
Personal Data processed: geographic position.
Category of Personal Information collected according to the CCPA: geolocation data.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
- a Sharing in California
-
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
-
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
-
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.
Google OAuth (Google Inc.)
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.
Personal Data processed: Tracker; 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 or other electronic network activity information.
This processing constitutes:
Linkedin OAuth (LinkedIn Corporation)
Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin 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 or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
-
Social features
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: address; city; country; date of birth; email address; first name; gender; geographic position; last name; phone number; picture; province; state.
Category of Personal Information collected according to the CCPA: identifiers; biometric information; geolocation data; audio, electronic, visual, thermal, olfactory, or similar information.
This processing constitutes:
-
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 Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information; inferences drawn from other personal information.
This processing constitutes:
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
-
General policy
Hearing Tracker, Inc. (“Hearing Tracker”) is committed to maintaining the integrity and privacy of your personal information collected through this website, hearingtracker.com (the “Website”). This Privacy Policy discloses Hearing Tracker’s information collection and dissemination practices in connection with the Website and applies solely to the information that we collect through the Website. This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business or investment relationship not handled through the Website).
Acceptance of Privacy Policy
By using the Website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use this Website. Your continued use of the Website following the posting of changes to these terms will mean that you accept those changes.
Personal Information Provided by You
How Personal Information Provided By You May Be Used
Except as described in this Privacy Policy, Hearing Tracker only collects your personally identifiable information (“PII”) through this Website when you choose to provide such information, such as when you create an account by signing up, or when you fill in the details of your personal profile. Information you share about yourself in written comments or on forums may also constitute PII. PII can include your name, photograph, date of birth, zip code and e-mail address. Please be aware that elements of your personally-submitted PII, such as your name, photograph, and approximate location may be shared publicly and/or with your hearing provider. When submitting your PII in conjunction with a provider-initiated hearing aid review, it may be possible for Hearing Tracker users and/or your hearing provider to connect elements of your PII to the de-identified information submitted by your provider (such as the model of hearing aids you wear, your audiogram results, etc). Hearing Tracker will promptly remove any PII upon request. Hearing Tracker may use your PII to:
- Address your requests for information, products or services;
- Provide you with a list of nearby professionals; based on your location;
- Administer your account;
- Provide you with access to particular tools and services;
- Mail or e-mail you information regarding products or services that we believe may be of interest to you; or
- Respond to your inquiries and send you administrative communications.
No Protected Health Information
Hearing Tracker does not intend to collect any protected health information (“PHI”) as such term is defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Hearing aid dispensers initiating hearing aid reviews through the Website should never include PHI in those reviews. In the event that any PHI is discovered by Hearing Tracker on the Website, it will be promptly removed.
Disclosures to Third Parties Assisting In Our Operations.
Hearing Tracker may share your PII under confidentiality agreements with other companies that work with, or on behalf of, Hearing Tracker to provide products and services. These companies may use your PII to assist Hearing Tracker in its operations. These companies do not, however, have any independent right to share this information.
Disclosures Under Special Circumstances.
We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise required by law.
Business Transfers.
We may share your PII with other business entities, in connection with the sale, assignment, merger or other transfer of all or a portion of Hearing Tracker’s business to such business entity. We will require any such successor business entity to honor the terms of this Privacy Policy.
Automatically Collected Information and Anonymous Information
Each time a visitor comes to the Website, Hearing Tracker collects some information to improve the overall quality of the visitor’s online experience.
Aggregated Data.
Hearing Tracker collects aggregate queries for internal reporting and also counts, tracks, and aggregates the visitor's activity into Hearing Tracker’s analysis of general traffic-flow at the Website. To these ends, Hearing Tracker may merge information about you into aggregated group data. In some cases, Hearing Tracker may remove personal identifiers from PII and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with Hearing Tracker’s affiliates, business partners, service providers and/or vendors; if it does so, Hearing Tracker will not disclose your individual identity.
Web Server Logs and IP Addresses.
An Internet Protocol (“IP”) address is a number that automatically identifies the computer/device you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. Hearing Tracker may use IP addresses to conduct website analyses and performance reviews and to administer the Website. Advertisements on the website may be targeted to regional groups of users by utilizing the IP address.
Cookies and Web Beacons.
Cookies are pieces of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Many websites use cookies as a standard practice to provide useful features when a user visits the website and most web browsers are set up to accept cookies. Hearing Tracker uses cookies to improve your online experience when visiting the Website. You can set your browser to refuse cookies, but some portions of the Website may not work properly if you refuse cookies. Some of the Website’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of websites. Some web beacons may be unusable if you elect to reject their associated cookies.
Referrals/Links
The Website may contain links to third-party websites that may offer information of interest. This Privacy Policy does not apply to those websites, and Hearing Tracker recommends reviewing those websites’ privacy policies individually. Hearing Tracker assumes no responsibility for any material outside of the Website, including any website that may be accessed through a link from the Website.
Security
Hearing Tracker understands that storing our data in a secure manner is essential. Hearing Tracker stores PII and other data using industry-standard physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Please note, however, that while Hearing Tracker has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to/from the Website or via e-mail cannot be guaranteed.
Children's Privacy Protection
Hearing Tracker understands the importance of protecting children's privacy in the interactive online world. The Website is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any PII to Hearing Tracker and/or the Website.
Changes
You may review and request changes to your PII that Hearing Tracker has collected, including the removal of your PII from Hearing Tracker’s databases in order to prevent receipt of future communications or to halt receipt of our Website services, using any of the following options:
You can send your request via e-mail to: info@hearingtracker.com
You can mail your request to the following postal address: Hearing Tracker, Inc., P.O. Box 40702, Austin, Texas 78704.
Policy Updates
This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display a version number and a date on the policy in the upper right corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any change to this Privacy Policy regarding use or disclosure of PII, we will provide advance notice on this Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
Questions?
If you have any questions about this Privacy Policy or about Hearing Tracker’s handling of your information, please contact info@hearingtracker.com
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
-
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
Usage Data, Tracker, Cookies, various types of Data as specified in the privacy policy of the service, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events, Trackers, session duration, scroll-to-page interactions, country, time zone, device information, interaction events, diagnostic events, page events, custom events, layout details, positional information, number of Users, session statistics, browser information
Purposes:
- Displaying content from external platforms
- Registration and authentication
- SPAM protection
- Analytics
- Further information about Personal Data
- Handling payments
- Hosting and backend infrastructure
- Heat mapping and session recording
- Tag Management
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google Inc., Facebook, Inc., Stripe Inc, DigitalOcean Inc., LinkedIn Corporation, Microsoft Corporation, Google LLC
Service providers or contractors: This Application
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
Usage Data, Tracker, answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position, touch events
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google Inc.
-
Identifiers
Personal Information collected or disclosed:
email address, first name, last name, phone number, address, gender, date of birth, geographic position, country, state, province, picture, city, Trackers, session duration, scroll-to-page interactions, clicks, time zone, device information, Usage Data, mouse movements, interaction events, diagnostic events, page events, custom events, layout details, positional information
Purposes:
- Contacting the User
- Managing contacts and sending messages
- Social features
- Heat mapping and session recording
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: The Rocket Science Group, LLC., Microsoft Corporation
Service providers or contractors: This Application
-
Geolocation data
Personal Information collected or disclosed:
geographic position, first name, last name, address, gender, date of birth, phone number, email address, country, state, province, picture, city
Purposes:
- Location-based interactions
- Social features
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: This Application
-
Biometric information
Personal Information collected or disclosed:
first name, last name, address, gender, date of birth, phone number, email address, geographic position, country, state, province, picture, city
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: This Application
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
first name, last name, address, gender, date of birth, phone number, email address, geographic position, country, state, province, picture, city
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: This Application
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this 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.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
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 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 California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.