Owner and Data Controller
The processing of personal data as described in this Privacy Policy is done by theConstruct BV. theConstruct BV is a private company with limited liability that falls under Dutch law and has its office at Postbus 10098, 1001 EB Amsterdam, the Netherlands.
If you have any questions about this Privacy Policy or about our processing of your personal data, please contact our data protection officer at dataprotectionoffice@theconstruct.io.
Owner contact email: info@theviewer.co
Types of Data collected
Among the types of Personal Data that theViewer Service collects, by itself or through third parties, there are:
email address; Usage Data; Data communicated while using the service; Tracker; device logs; device information; first name; last name; company name; geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Approximate location permission (continuous); Microphone permission; Sensors permission; Storage permission; Motion sensors permission; Write-only Photo Library permission; payment info; billing address; purchase history; various types of Data; password; Read metadata.
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 theViewer Service.
Unless specified otherwise, all Data requested by theViewer Service is mandatory and failure to provide this Data may make it impossible for theViewer Service to provide its services. In cases where theViewer Service 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 theViewer Service or by the owners of third-party services used by theViewer Service 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 theViewer Service.
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 theViewer Service (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:
Beta Testing, Analytics, Contacting the User, Hosting and backend infrastructure, Registration and authentication provided directly by theViewer Service, Location-based interactions, Remarketing and behavioral targeting, Tag Management, Device permissions for Personal Data access, Social features, Advertising, Handling payments, Data transfer outside the EU, Content performance and features testing (A/B testing), Displaying content from external platforms, Registration and authentication, Infrastructure monitoring, Platform services and hosting, Managing support and contact requests and Managing contacts and sending messages.
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”.
Device permissions for Personal Data access
Depending on the User's specific device, theViewer Service may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of theViewer Service.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by theViewer Service.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. TheViewer Service may collect, use, and share User location Data in order to provide location-based services.
Microphone permission
Allows accessing and recording microphone audio from the User's device.
Motion sensors permission
Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).
Sensors permission
Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Write-only Photo Library permission
Allows write-only access to the User's photo library.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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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 theViewer Service, 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 for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. 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.
Meta ads conversion tracking (Meta pixel)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on theViewer Service. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Unity Analytics (Unity Technologies ApS)
Unity Analytics is an analytics service provided by Unity Technologies ApS.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Contract.
Place of processing: Denmark – Privacy Policy.
User ID extension for Google Analytics
Google Analytics on theViewer Service 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 theViewer Service.
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: Tracker.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features
Google Analytics on theViewer Service has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
TheViewer Service uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
theViewer Analytics
Personal Data collected
Anonymized User ID
Usage data
Privacy Policy
theViewer Analytics is a heat mapping service provided by theConstruct B.V.. theConstruct B.V. utilizes the Data collected to analyze and examine the use of theViewer Service, to prepare reports on its activities, and share them with the content owner.
theConstruct B.V. may use the Data collected to contextualize and personalize the data stored on theViewer Service.
Place of processing: EU – Privacy Policy of theViewer Service
Opt-Out: Please clean cache of native theViewer app or web browser for theviewer.co web page or Update consent preferences on theviewer.co footer. After that, no more data will be collected and after that activity, you will be again asked to state your consent about sharing analytical data with theViewer Service.
Legal basis for processing: Consent.
Legal basis for data transfer: No data transfer.
Google Analytics with anonymized IP
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of theViewer Service, 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: Tracker; Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Analytics for Apps
Facebook Analytics for Apps is an analytics service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing,
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Beta Testing
This type of service makes it possible to manage User access to theViewer Service, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of theViewer Service in a personally identifiable form.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: Data communicated while using the service; device information; device logs; email address; Tracker; Usage Data.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy.
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Contacting the User
Mailing list or newsletter (theViewer Service)
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 theViewer Service. Your email address might also be added to this list as a result of signing up to theViewer Service or after making a purchase.
Personal Data processed: email address; first name; last name.
Legal basis for processing: Consent.
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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 theViewer Service.
Google Optimize
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: Tracker; Usage Data.
Legal basis for processing: Statistical purposes.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (theViewer Service)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List.
Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
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Device permissions for Personal Data access
TheViewer Service requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (theViewer Service)
TheViewer Service requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Microphone permission; Motion sensors permission; Sensors permission; Storage permission; Write-only Photo Library permission.
Legal basis for processing: Consent.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of theViewer Service 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 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 theViewer Service to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Handling payments
Unless otherwise specified, theViewer Service processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. TheViewer Service isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe ( Stripe Technology Europe Ltd)
Stripe is a payment service provided by Stripe Technology Europe Ltd.
Personal Data processed: billing address; email address; first name; last name; payment info; purchase history.
Legal basis for processing: Contract.
Place of processing: Ireland – Privacy Policy.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable theViewer Service to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of theViewer Service.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; Australia – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
Photon Engine Cloud (Exit Games Inc)
Photon Engine Cloud is a hosting and backend service provided by Exit Games Inc.
Personal Data processed: various types of Data.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Google BigQuery (Google Ireland Limited)
Google BigQuery is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: Ireland – Privacy Policy.
Data retention period: Keeping the Data for the time necessary to fulfill statistical purposes.
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Infrastructure monitoring
This type of service allows theViewer Service to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of theViewer Service.
Datadog (Datadog, Inc.)
Datadog is a monitoring service provided by Datadog, Inc.
The way Datadog is integrated means that it filters all traffic of theViewer Service, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on theViewer Service to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Statistical purposes.
Place of processing: United States – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
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Location-based interactions
Geolocation (theViewer Service)
TheViewer Service 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 theViewer Service.
Personal Data processed: geographic position.
Legal basis for processing: Statistical purposes.
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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 (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: Data communicated while using the service; email address.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy.
Amazon Simple Email Service (Amazon Europe )
Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
Personal Data processed: email address.
Legal basis for processing: Contract.
Place of processing: Luxembourg – Privacy Policy.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
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Managing support and contact requests
This type of service allows theViewer Service 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.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of theViewer Service, therefore allowing the provision of theViewer Service 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.
Apple App Store (Apple Inc.)
TheViewer Service is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of theViewer Service. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Google Play Store
TheViewer Service is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Webflow (Webflow, Inc.)
Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host theViewer Service. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
Personal Data processed: Tracker; Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt out.
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Registration and authentication
By registering or authenticating, Users allow theViewer Service 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, theViewer Service will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Firebase Authentication
Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; password.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
Google OAuth
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.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
Gmail permissions to access User Data (OAuth addition)
To provide its service, theViewer Service uses restricted scopes for Gmail which allow access to User Data related to this Google service (as indicated below). This access is provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, under strict terms. Here's what this means for such User Data:
- The use of User Data is limited to providing or improving User-facing features. User Data will not be used for serving ads, including retargeting, personalized, or interest-based advertising.
- User Data will be transferred to third parties only if necessary, to provide or improve User-facing features and as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to Users.
- Humans will not read the Data unless:
- the Owner has obtained the User's affirmative agreement for specific messages;
- it is necessary for security purposes and/or to comply with applicable law, or;
- the use is limited to internal operations and the Data (including derivations) have been aggregated and anonymized.
Personal Data processed: Read metadata.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Facebook Oauth
Facebook Oauth is a registration and authentication service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, 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.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Legal basis for data transfer: Standard data protection clauses.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
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Registration and authentication provided directly by theViewer Service
By registering or authenticating, Users allow theViewer Service to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (theViewer Service)
The User registers by filling out the registration form and providing the Personal Data directly to theViewer Service.
Personal Data processed: company name; email address; first name; last name.
Legal basis for processing: Contract.
Data retention period: Keeping the Data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).
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Remarketing and behavioral targeting
This type of service allows theViewer Service and its partners to inform, optimize and serve advertising based on past use of theViewer Service by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Remarketing with Google Analytics
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 Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of theViewer Service with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of theViewer Service with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing
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 theViewer Service with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Data retention period: Keeping the Data for the time necessary to fulfill the purpose.
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Social features
Firebase Dynamic Links
Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within theViewer Service.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Legal basis for processing: Contract.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on theViewer Service 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 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: Tracker; Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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
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User identification via a universally unique identifier (UUID)
TheViewer Service may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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Unique device identification
TheViewer Service may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
Cookie Policy
TheViewer Service 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 Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running theViewer Service and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
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 theViewer Service 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, theViewer Service 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, theViewer Service and any third-party services may collect files that record interaction with theViewer Service (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 theViewer Service and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through theViewer Service (or third-party services employed in theViewer Service), which can include: the IP addresses or domain names of the computers utilized by the Users who use theViewer Service, 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 theViewer Service 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 theViewer Service. The Data Controller, unless otherwise specified, is the Owner of theViewer Service.
theViewer Service (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by theViewer Service as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Read metadata
Read resources metadata including labels, history records, and email message headers, but not the message body or attachments.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to theViewer Service, if not stated otherwise within this document.