Policy summary
Personal Data processed for the following purposes and using the following services:
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Access to third-party accounts
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Facebook account access
Permissions: About Me; Access Friend Lists; Access Page CTA; Access private data; Access Requests; Activities; App Notifications; Birthday; Books Actions; Business Management API; Chat; Checkins; Contact email; Create Events; Create notes; Current City; Custom Friend Lists Access; Custom User Actions; Deals; Education History; Email; Events; Export Posts; Family Members and Relationship Status; Fitness Actions; Friend subscriptions; Friends' About Me; Friends' Activities; Friends' birthdays; Friends' Checkins; Friends' Current Cities; Friends' Custom User Actions; Friends' Education History; Friends' Events; Friends' Family Members and Relationship Status; Friends' Games and App Activity; Friends' Groups; Friends' Hometown; Friends' Interests; Friends' Likes; Friends' music.listens Actions; Friends' news.read Actions; Friends' Notes; Friends' Online Presence; Friends' Photos; Friends' Questions; Friends' Religious and Political Views; Friends' Significant Others and Relationship Details; Friends' Statuses; Friends' video.watches Actions; Friends' Videos; Friends' Websites; Friends' Work History; Games and App Activity; Gender; Groups; Hometown; Insights; Interests; Likes; List of Friends; Manage Advertisements; Manage Friend Lists; Manage Groups; Manage Mailbox; Manage Notifications; Manage Pages; Mobile Messaging on behalf of Page; music.listen Action; News Feed and Wall; news.read Actions; Notes; Offline Access; Online Presence; Page Messaging; Photos; Post Likes to my Wall; Publish App Activity; Publish as Page; Publish Checkins; Publish to the Wall; Questions; Read Group Content; Read Mailbox; Read page mailbox; Religious and Political Views; RSVP to Events; Share; Show List of Managed Pages; Significant Other and Relationship Details; Status; Status Updates; Tagged Places; Text Messaging; Upload Photos; User subscriptions; User Timeline Posts Access; Video upload; video.watches Action; Videos; Website; Work History
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Dropbox account access, Google Drive account access, Stripe account access and Twitter account access
Personal Data: various types of Data as specified in the privacy policy of the service
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Backup saving and management
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Contacting the User
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Contact form
Personal Data: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; User ID; various types of Data; website; ZIP/Postal code
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Mailing list or newsletter
Personal Data: address; city; company name; Cookies; country; county; date of birth; email address; first name; gender; last name; phone number; profession; state; Usage Data; website
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Phone contact
Personal Data: phone number
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Content commenting
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Comment system managed directly
Personal Data: Cookies; email address; first name; last name; phone number; Usage Data; username; website
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Disqus and Livefyre
Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service
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Facebook Comments
Personal Data: Cookies; Usage Data
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IntenseDebate
Personal Data: Cookies; email address; Usage Data
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Muut
Personal Data: Usage Data
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Content performance and features testing (A/B testing)
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Data transfer outside the EU
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Device permissions for Personal Data access
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Displaying content from external platforms
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Adobe Fonts, Fonts.com Web Fonts and Google Fonts
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
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GitHub button and social widgets, SoundCloud widget and YouTube video widget without cookies
Personal Data: Usage Data
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Google Calendar widget, Google Maps widget, Google Programmable Search Engine, Instagram widget, Mapbox widget, Spotify widget, Storify widget, TripAdvisor widget, Vimeo video, YouTube video widget, Vine widget and HERE Maps widget
Personal Data: Cookies; Usage Data
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Gravatar
Personal Data: email address; Usage Data
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Hosting and backend infrastructure
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Infrastructure monitoring
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Firebase Performance Monitoring and Firebase Crash Reporting
Personal Data: various types of Data as specified in the privacy policy of the service
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Crashlytics
Personal Data: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service
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Interaction with data collection platforms and other third parties
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Interaction with external social networks and platforms
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Interaction with live chat platforms
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Interaction with online survey platforms
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Interaction with support and feedback platforms
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Location-based interactions
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Managing contacts and sending messages
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Campaign Monitor
Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username
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BulkSMS
Personal Data: phone number
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Mailchimp
Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data
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Managing landing and invitation pages
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Mailchimp Landing Page
Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username
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Leadpages
Personal Data: email address; Usage Data; various types of Data as specified in the privacy policy of the service
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Managing support and contact requests
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Platform services and hosting
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Registration and authentication
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Direct registration
Personal Data: academic background; address; billing address; budget; city; company name; country; county; data relating to the point of sale; date of birth; email address; fax number; field of activity; first name; gender; house number; language; last name; marital status; number of employees; password; phone number; picture; prefix ; profession; profile picture; shipping address; state; Twitter handle; User ID; username; various types of Data
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Facebook Authentication, GitHub OAuth, Instagram Authentication, Mailchimp OAuth, OneDrive OAuth, Twitter OAuth, Windows Live Connect, YouTube OAuth, Pinterest OAuth, Meetup.com OAuth, Linkedin OAuth, Google OAuth and Foursquare OAuth
Personal Data: various types of Data as specified in the privacy policy of the service
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Firebase Authentication
Personal Data: email address; first name; last name; password; phone number; profile picture; social media accounts ; username
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Remarketing and behavioral targeting
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Social features
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Public profile
Personal Data: address; city; company name; country; county; date of birth; email address; first name; gender; geographic position; last name; phone number; picture; profession; state; username
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Inviting and suggesting friends
Personal Data: various types of Data
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Firebase Invites and Firebase Dynamic Links
Personal Data: various types of Data as specified in the privacy policy of the service
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Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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Access the address book
This Application may request access to your address book.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
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Personal Data collected through sources other than the User
The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
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Privacy Shield participation: data transfers from the EU and Switzerland to the United States
The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States.
The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise.
The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).
What does this mean for the European User?
The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.
This, most importantly, includes the right of individuals to access their personal data processed by the Owner.
The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.
The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Dispute resolution under the Privacy Shield
In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.
In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.
In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.
Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.
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Push notifications
This Application may send push notifications to the User.
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The Service is directed to children under the age of 13
This Application is directed to children under the age of 13. It doesn't require the child to disclose any more information than is reasonably necessary to participate in its activity.
Parents may review the personal information about their child collected by this Application - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow disclosure to third parties, unless disclosure is integral to the Service.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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User identification via a universally unique identifier (UUID)
This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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Owner and Data Controller
Lets Wandr PTY LTD
PO BOX 1035 Burwood North 2134
Burwood NSW 2134, Australia
Data Protection Office(DPO)
Represented by:
Mitry Lawyers Sydney, Australia
Lawyer: Richard Mitry(Partner)
+61 2 9222 2833
email: richard@mitry.com.au
Owner contact email: allen@letswandr.com
Full policy
Owner and Data Controller
Lets Wandr PTY LTD
PO BOX 1035 Burwood North 2134
Burwood NSW 2134, Australia
Data Protection Office(DPO)
Represented by:
Mitry Lawyers Sydney, Australia
Lawyer: Richard Mitry(Partner)
+61 2 9222 2833
email: richard@mitry.com.au
Owner contact email: allen@letswandr.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
first name; last name; gender; date of birth; phone number; company name; profession; address; fax number; country; state; county; email address; ZIP/Postal code; various types of Data; city; field of activity; User ID; number of employees; website; Cookies; Usage Data; Data communicated while using the service; app information; device information; device logs; username; Calendar permission; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Phone permission; Sensors permission; SMS permission; Storage permission; Reminders permission; HomeKit permission; Motion sensors permission; Bluetooth sharing permission; Social media accounts permission; general activity data; movement activity; food related activity ; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geographic position; password; picture; marital status; billing address; shipping address; house number; prefix ; data relating to the point of sale; language; profile picture; Twitter handle; budget; academic background; social media accounts .
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Contacting the User, Access to third-party accounts, Interaction with external social networks and platforms, Analytics, Commercial affiliation, Beta Testing, Backup saving and management, Content commenting, Content performance and features testing (A/B testing), Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Handling activity data, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with data collection platforms and other third parties, Interaction with live chat platforms, Interaction with online survey platforms, Interaction with support and feedback platforms, Location-based interactions, Managing contacts and sending messages, Managing landing and invitation pages, Managing support and contact requests, Platform services and hosting, Registration and authentication, Remarketing and behavioral targeting, Social features, SPAM protection, Tag Management and User database management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Access Page CTA
Provides the access to manage call to actions on User-managed Pages.
Access private data
Access the User's and friends' private data.
Access Requests
Provides read access to the User's friend requests.
Activities
Provides access to the User's list of activities.
App Notifications
Send notifications.
Birthday
Provides access to the birthday.
Books Actions
Business Management API
Read and write with Business Management API.
Chat
Provides applications that integrate with Facebook Chat the ability to log in Users.
Checkins
Provides read access to the authorized User's check-ins.
Contact email
Access the User's contact email address.
Create Events
Enables the application to create and modify events on the User's behalf.
Create notes
Add or modify notes.
Current City
Provides access to the User's current location.
Custom Friend Lists Access
Provides access to the names of custom lists the User has created to organize their friends.
Custom User Actions
Allows the app retrieve the actions published by another application as specified by the app namespace.
Deals
Read the deal activity.
Education History
Provides access to education history.
Email
Provides access to the User's primary email address.
Events
Provides access to the list of events the User is attending.
Export Posts
Export the posts and make them public. All posts will be exported, including status updates.
Family Members and Relationship Status
Provides access to the User's family and personal relationships and relationship status.
Fitness Actions
Friend subscriptions
Friends' About Me
Provides access to the 'About Me' section of the friends' profile.
Friends' Activities
Provides access to the friends' list of activities.
Friends' birthdays
Provides access to the friends' birthdays.
Friends' Checkins
Provides read access to the friends' check-ins that the User can see.
Friends' Current Cities
Provides access to the friends' current locations.
Friends' Custom User Actions
Allows the app to retrieve the actions published by another application as specified by the app namespace.
Friends' Education History
Provides access to friends' education history.
Friends' Events
Provides access to the list of events the friends are attending.
Friends' Family Members and Relationship Status
Provides access to a friend's family and personal relationships and relationship status.
Friends' Games and App Activity
Allows the app post and retrieve game achievement activity.
Friends' Groups
Provides access to the list of groups the User's friends are a members of.
Friends' Hometown
Provides access to the friends' hometown.
Friends' Interests
Provides access to the friends' lists of interests.
Friends' Likes
Provides access to the list of all of the pages the friends have liked.
Friends' music.listens Actions
Allows the app to retrieve the actions published by all applications using the built-in music.listens action.
Friends' news.read Actions
Allows the app to retrieve the actions published by all applications using the built-in news.reads action.
Friends' Notes
Provides access to the friends' notes.
Friends' Online Presence
Provides access to the User's friend's online/offline presence.
Friends' Photos
Provides access to the photos the friends have uploaded, and photos the friends have been tagged in.
Friends' Questions
Provides access to the questions the friends have asked.
Friends' Religious and Political Views
Provides access to the friends' religious and political affiliations.
Friends' Significant Others and Relationship Details
Provides access to the friends' relationship preferences.
Friends' Statuses
Provides access to the friends' status messages and checkins.
Friends' video.watches Actions
Allows the app to retrieve the actions published by all applications using the built-in video.watches action.
Friends' Videos
Provides access to the videos the friends have uploaded and have been tagged in.
Friends' Websites
Provides access to the friends' web site URLs.
Friends' Work History
Provides access to a friend's work history.
Games and App Activity
Allows the app post and retrieve game achievement activity.
Gender
Groups
Provides access to the list of groups the User is a member of.
Hometown
Provides access to the User's hometown.
Insights
Provides read access to the Insights data for pages, applications, and domains the user owns.
Interests
Provides access to the User's list of interests.
Likes
Provides access to the list of all of the pages the User has liked.
List of Friends
Manage Advertisements
Provides the ability to manage ads and call the Facebook Ads API on behalf of a User.
Manage Friend Lists
Enables the app to create, delete and edit the User's friend lists.
Manage Groups
Manage the User's groups.
Manage Mailbox
Read and send messages from the User's mailbox.
Manage Notifications
Enables the app to read notifications and mark them as read.
Manage Pages
Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.
Mobile Messaging on behalf of Page
Send and receive mobile messages on behalf of a Facebook Page.
music.listen Action
Allows the app to retrieve the actions published by all applications using the built-in music.listens action.
News Feed and Wall
Provides access to all the posts in the User's News Feed and enables the application to perform searches against the User's News Feed.
news.read Actions
Allows the app to retrieve the actions published by all applications using the built-in news.reads action.
Notes
Provides access to the User's notes.
Offline Access
Access the data when the User is not using the application.
Online Presence
Provides access to the User's online/offline presence.
Page Messaging
Send and receive messages through a Facebook Page.
Photos
Provides access to the photos the User has uploaded, and photos the User has been tagged in.
Post Likes to my Wall
Publish stories about things the User Likes to the Wall.
Publish App Activity
Allows the app to publish to the Open Graph using Built-in Actions, Achievements, Scores, or Custom Actions. The app can also publish other activity which is detailed in the Facebook's Publishing Permissions document.
Publish as Page
Enables the ability to post, comment and like as any of the Pages managed by the User.
Publish Checkins
Enables the app to perform checkins on behalf of the User.
Publish to the Wall
Enables the app to post content, comments, and likes to a User's stream and to the streams of the User's friends.
Questions
Provides access to the questions the User has asked.
Read Group Content
Lets the app read content in a group managed by the User.
Read Mailbox
Provides the ability to read from a user's Facebook Inbox.
Read page mailbox
Religious and Political Views
Provides access to the User's religious and political affiliations.
RSVP to Events
Enables the application to RSVP to events on the User's behalf.
Share
Share items on the User's behalf.
Show List of Managed Pages
Provides the access to show the list of the Pages that the User manages.
Significant Other and Relationship Details
Provides access to the User's relationship preferences.
Status
Provides access to the User's status messages and checkins.
Status Updates
Update the User's status.
Tagged Places
Text Messaging
Send SMS messages to the User's phone.
Upload Photos
Add or modify user's photos.
User subscriptions
User Timeline Posts Access
Provides access to the posts on a Users's timeline.
Video upload
Add or modify User's videos.
video.watches Action
Allows the app to retrieve the actions published by all applications using the built-in video.watches action.
Videos
Provides access to the videos the User has uploaded and videos the User has been tagged in.
Website
Provides access to the User's web site URL.
Work History
Provides access to work history.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.
Bluetooth sharing permission
Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Contacts permission
Used for accessing contacts and profiles on the User's device, including the changing of entries.
HomeKit permission
Used for accessing the HomeKit framework and enabling this app to interact with physical accessories in the User's surrounding environment.
Microphone permission
Used for 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.).
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Precise location permission (continuous)
Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Precise location permission (non-continuous)
Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.
Reminders permission
Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.
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.
SMS permission
Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access Friend Lists; Access Page CTA; Access private data; Access Requests; Activities; App Notifications; Birthday; Books Actions; Business Management API; Chat; Checkins; Contact email; Create Events; Create notes; Current City; Custom Friend Lists Access; Custom User Actions; Deals; Education History; Email; Events; Export Posts; Family Members and Relationship Status; Fitness Actions; Friend subscriptions; Friends' About Me; Friends' Activities; Friends' birthdays; Friends' Checkins; Friends' Current Cities; Friends' Custom User Actions; Friends' Education History; Friends' Events; Friends' Family Members and Relationship Status; Friends' Games and App Activity; Friends' Groups; Friends' Hometown; Friends' Interests; Friends' Likes; Friends' music.listens Actions; Friends' news.read Actions; Friends' Notes; Friends' Online Presence; Friends' Photos; Friends' Questions; Friends' Religious and Political Views; Friends' Significant Others and Relationship Details; Friends' Statuses; Friends' video.watches Actions; Friends' Videos; Friends' Websites; Friends' Work History; Games and App Activity; Gender; Groups; Hometown; Insights; Interests; Likes; List of Friends; Manage Advertisements; Manage Friend Lists; Manage Groups; Manage Mailbox; Manage Notifications; Manage Pages; Mobile Messaging on behalf of Page; music.listen Action; News Feed and Wall; news.read Actions; Notes; Offline Access; Online Presence; Page Messaging; Photos; Post Likes to my Wall; Publish App Activity; Publish as Page; Publish Checkins; Publish to the Wall; Questions; Read Group Content; Read Mailbox; Read page mailbox; Religious and Political Views; RSVP to Events; Share; Show List of Managed Pages; Significant Other and Relationship Details; Status; Status Updates; Tagged Places; Text Messaging; Upload Photos; User subscriptions; User Timeline Posts Access; Video upload; video.watches Action; Videos; Website; Work History.
Place of processing: United States – Privacy Policy.
Dropbox account access (Dropbox, Inc.)
This service allows this Application to connect with the User's account on Dropbox, provided by Dropbox, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Drive account access (Google LLC)
This service allows this Application to connect with the User's account on Google Drive, provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Stripe account access (Stripe Inc)
This service allows this Application to connect with the User's account on Stripe, provided by Stripe, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Twitter account access (X Corp.)
This service allows this Application to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics 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.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics with anonymized IP (Google LLC)
Google Analytics 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.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Business Contact (Italiaonline S.p.A.)
Business Contact is an analytics service provided by Italiaonline S.p.A.
Personal Data processed: Cookies; Usage Data.
Place of processing: Italy – Privacy Policy.
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Backup saving and management
This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
Backup on Dropbox (Dropbox, Inc.)
Dropbox is a service to save and manage backups provided by Dropbox Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Backup on Google Drive (Google LLC)
Google Drive is a service to save and manage backups provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Amazon Glacier (Amazon)
Amazon Glacier is a service to save and manage backups provided by Amazon Web Services Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Vaultpress (Automattic Inc.)
Vaultpress is a service to save and manage backups provided by Automattic Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Beta Testing
This type of service makes it possible to manage User access to this Application, 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 this Application in a personally identifiable form.
Beta by Crashlytics (Google LLC)
Beta by Crashlytics is a beta testing service provided by Google LLC.
Personal Data processed: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Commercial affiliation
This type of service allows this Application to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Application.
For details of which data are collected, please refer to the privacy policy of each service.
Booking.com Affiliate Partner Programme (Booking.com B.V.)
Booking.com Affiliate Partner Programme is a commercial affiliation service provided by Booking.com B.V., part of the Priceline.com group.
Personal Data processed: Cookies; Usage Data.
Place of processing: Netherlands – Privacy Policy.
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Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; User ID; various types of Data; website; ZIP/Postal code.
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: address; city; company name; Cookies; country; county; date of birth; email address; first name; gender; last name; phone number; profession; state; Usage Data; website.
Phone contact (this Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (this Application)
This Application has its own internal content comment system.
Personal Data processed: Cookies; email address; first name; last name; phone number; Usage Data; username; website.
Disqus (Disqus)
Disqus is a content commenting service provided by Big Heads Labs Inc.
Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
IntenseDebate (Automattic Inc.)
IntenseDebate is a content commenting service provided by Automattic Inc.
Personal Data processed: Cookies; email address; Usage Data.
Place of processing: United States – Privacy Policy.
Livefyre (Livefyre)
Livefyre is a content commenting service provided by Livefyre Inc.
Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Muut (Muut, Inc.)
Muut is a content commenting and forum service provided by Muut, Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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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 this Application.
Firebase Remote Config (Google LLC)
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – 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 abroad based on consent (this Application)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Personal Data processed: various types of Data.
Data transfer abroad based on standard contractual clauses (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List.
Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
Data transfer to countries that guarantee European standards (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Personal Data processed: various types of Data.
Other legal basis for Data transfer abroad (this Application)
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.
Personal Data processed: various types of Data.
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Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; Calendar permission; Camera permission; Contacts permission; HomeKit permission; Microphone permission; Motion sensors permission; Phone permission; Precise location permission (continuous); Precise location permission (non-continuous); Reminders permission; Sensors permission; SMS permission; Social media accounts permission; Storage permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Adobe Fonts (Adobe Systems Incorporated)
Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)
Fonts.com Web Fonts is a typeface visualization service provided by Monotype Imaging Holdings Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
GitHub button and social widgets (GitHub Inc.)
The GitHub button and social widgets are services allowing interaction with the GitHub and Gist services provided by GitHub, Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Google Calendar widget (Google LLC)
Google Calendar widget is a calendar content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Google Programmable Search Engine (Google LLC)
Google Programmable Search Engine is a search engine embedding service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Mapbox widget (Mapbox Inc.)
Mapbox is a maps visualization service provided by Mapbox Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
SoundCloud widget (SoundCloud Limited)
Soundcloud is an audio content delivery service provided by SoundCloud Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: Germany – Privacy Policy.
Spotify widget (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: Sweden – Privacy Policy.
Storify widget (Storify, Inc. )
Storify is a content visualization service provided by Storify, Inc. that allows this Application to incorporate content from external platforms on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
TripAdvisor widget (TripAdvisor LLC)
TripAdvisor widget is a content visualization service provided by TripAdvisor LLC that allows this Application to incorporate content from that external platform on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube video widget without cookies (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on this Application unless they play the video.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Vine widget (Vine Labs, Inc.)
Vine is a video content visualization service provided by Vine Labs, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
HERE Maps widget (HERE Global B.V)
HERE Maps is a maps visualization service provided by HERE Global B.V that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: Netherlands – Privacy Policy.
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Handling activity data
This type of service allows the Owner to use the activity data collected by your device in order for this Application to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.
Activity data tracked by your device (this Application)
This Application uses some activity data tracked by your device to operate or to provide specific features.
Personal Data processed: date of birth; food related activity ; gender; general activity data; movement activity.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Canada – Privacy Policy; Brazil – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy; India – Privacy Policy; Australia – Privacy Policy; China – Privacy Policy; Korea, Republic of – Privacy Policy; Japan – Privacy Policy; Singapore – Privacy Policy.
Firebase Cloud Firestore (Google LLC)
Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Cloud Functions (Google LLC)
Firebase Cloud Functions is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Cloud Storage (Google LLC)
Firebase Cloud Storage is a hosting service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Hosting (Google LLC)
Firebase Hosting is a hosting service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Legacy (Firebase, Inc.)
Firebase is a hosting and backend service provided by Firebase, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Realtime Database (Google LLC)
Firebase Realtime Database is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
GitHub Pages (GitHub Inc.)
GitHub Pages is a hosting service provided by GitHub, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Cloud Storage (Google LLC)
Google Cloud Storage is a hosting service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Canada – Privacy Policy; Brazil – Privacy Policy; Belgium – Privacy Policy; United Kingdom – Privacy Policy; Germany – Privacy Policy; Netherlands – Privacy Policy; Taiwan – Privacy Policy; Japan – Privacy Policy; India – Privacy Policy; Singapore – Privacy Policy; Australia – Privacy Policy.
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Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Firebase Performance Monitoring (Google LLC)
Firebase Performance Monitoring is a monitoring service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Crash Reporting (Google LLC)
Firebase Crash Reporting is a monitoring service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Crashlytics (Google LLC)
Crashlytics is a monitoring service provided by Google LLC.
Personal Data processed: geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Mailchimp widget (The Rocket Science Group LLC)
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: Cookies; email address; first name; last name; phone number; Usage Data.
Place of processing: United States – Privacy Policy.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Google+ +1 button and social widgets (Google LLC)
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google LLC.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Pinterest “Pin it” button and social widgets (Pinterest)
The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
AddThis (Oracle Corporation)
AddThis is a service provided by Oracle Corporation, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
AddToAny (AddToAny LLC)
AddToAny is a service provided by AddToAny LLC, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube button and social widgets (Google LLC)
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
ShareThis (Sharethis Inc.)
ShareThis is a service provided by ShareThis Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Socialize (Solialize Inc.)
Socialize is a service provided by Socialize, Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Reddit button and widgets (reddit inc.)
The reddit button and widgets are services allowing interaction with the reddit platform provided by reddit inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, for contacting and being contacted by this Application support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Facebook Messenger Customer Chat (Facebook, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
LiveChat Widget (LiveChat, Inc.)
The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
My LiveChat Widget (CuteSoft Components Inc.)
The My LiveChat Widget is a service for interacting with the My LiveChat live chat platform provided by CuteSoft Components Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: Canada – Privacy Policy.
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Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
SurveyMonkey Widget (SurveyMonkey Inc.)
The SurveyMonkey Widget is a service for interacting with the SurveyMonkey online survey platform provided by SurveyMonkey Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Customerly Survey Widget (Customerly Ltd.)
The Customerly Survey Widget is a service for interacting with the Customerly online survey platform provided by Customerly Ltd.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Application.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Zendesk Widget (Zendesk, Inc.)
The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username.
Place of processing: United States – Privacy Policy.
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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.
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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.
Campaign Monitor (Campaign Monitor Pty Ltd)
Campaign Monitor is an email address management and message sending service provided by Campaign Monitor Pty Ltd.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username.
Place of processing: Australia – Privacy Policy.
BulkSMS (this Application)
BulkSMS is a phone numbers management and communication service provided by
- Celerity Europe AG;
- Celerity Systems Ltd;
- Celerity Messaging Ltd.
Personal Data processed: phone number.
Place of processing: various places depending on the company that provides the service – Privacy Policy.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data.
Place of processing: United States – Privacy Policy.
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Mailchimp Landing Page (The Rocket Science Group LLC)
Mailchimp Landing Page is a landing page management service provided by The Rocket Science Group LLC, that allows this Application to collect the email addresses of Users interested in its service.
Mailchimp Landing Page allows 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 the created landing pages.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username.
Place of processing: United States – Privacy Policy.
Leadpages (Avenue 81, Inc.)
Leadpages is a landing page management service provided by Avenue 81, Inc., that allows this Application to collect the email addresses of Users interested in its service.
Leadpages allows 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 the created landing pages.
Personal Data processed: email address; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
ZOHO CRM Email
ZOHO CRM Email is a support and contact request management service provided by Zoho Corporation Pvt. Ltd. or by ZOHO Corporation B.V, 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: United States – Privacy Policy; Netherlands – Privacy Policy.
Salesforce Service Cloud (salesforce.com, inc.)
Salesforce Service Cloud is a support and contact request management service provided by salesforce.com, inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed: academic background; address; billing address; budget; city; company name; country; county; data relating to the point of sale; date of birth; email address; fax number; field of activity; first name; gender; house number; language; last name; marital status; number of employees; password; phone number; picture; prefix ; profession; profile picture; shipping address; state; Twitter handle; User ID; username; various types of Data.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Authentication (Google LLC)
Firebase Authentication is a registration and authentication service provided by Google LLC.
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; phone number; profile picture; social media accounts ; username.
Place of processing: United States – Privacy Policy.
GitHub OAuth (GitHub Inc.)
GitHub OAuth is a registration and authentication service provided by GitHub Inc. and is connected to the GitHub network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Instagram Authentication (Instagram, Inc.)
Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Mailchimp OAuth (The Rocket Science Group LLC)
Mailchimp OAuth is a registration and authentication service provided by The Rocket Science Group LLC and is connected to the Mailchimp service.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
OneDrive OAuth (Microsoft Corporation)
OneDrive OAuth is a registration and authentication service provided by Microsoft Corporation and is connected to the OneDrive network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Twitter OAuth (X Corp.)
Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Windows Live Connect (Microsoft Corporation)
Microsoft Live Connect is a registration and authentication service provided by Microsoft Corporation and is connected to the Microsoft network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
YouTube OAuth (Google LLC)
YouTube OAuth is a registration and authentication service provided by Google LLC and is connected to the YouTube network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Pinterest OAuth (Pinterest)
Pinterest OAuth is a registration and authentication service provided by Pinterest, Inc. and is connected to the Pinterest social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Meetup.com OAuth (Meetup Inc.)
Meetup.com OAuth is a registration and authentication service provided by Meetup Inc. and is connected to the Meetup.com network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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: United States – Privacy Policy.
Google OAuth (Google LLC)
Google OAuth is a registration and authentication service provided by Google LLC 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: United States – Privacy Policy.
Foursquare OAuth (Foursquare Labs, Inc.)
Foursquare Oauth is a registration and authentication service provided by Foursquare Labs, Inc. and is connected to the Foursquare network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension (Google LLC)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
AdRoll (AdRoll, Inc.)
AdRoll is an advertising service provided by AdRoll, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Salesforce DMP (salesforce.com, inc.)
Salesforce DMP is a remarketing and behavioral targeting service provided by salesforce.com, inc.
Salesforce DMP makes use of tracking technologies to monitor User behavior. This Data is then used to personalize the User's experience and to provide targeted advertising. Salesforce DMP may also connect the collected Data with other networks, including advertising networks, and enable these parties to track and target the User. The Owner, unless otherwise specified in this document, has no direct relationship with the third parties that Salesforce DMP may be including.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tailored Audiences (X Corp.)
Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy.
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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; company name; country; county; date of birth; email address; first name; gender; geographic position; last name; phone number; picture; profession; state; username.
Inviting and suggesting friends (this Application)
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
Firebase Invites (Google LLC)
Firebase Invites is a social feature provided by Google LLC that enables Users to share this Application. The sharing may contain referral codes, or content from within this Application and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed this Application via invite.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Dynamic Links (Google LLC)
Firebase Dynamic Links is a social feature provided by Google LLC.
Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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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.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
ZOHO CRM
ZOHO CRM is a User database management service provided by Zoho Corporation Pvt. Ltd. or by ZOHO Corporation B.V, depending on how the Owner manages the Data processing.
Personal Data processed: email address; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Netherlands – Privacy Policy.
Salesforce Sales Cloud (salesforce.com, inc.)
Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Salesforce Marketing Cloud (salesforce.com, inc.)
Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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Access the address book
This Application may request access to your address book.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
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Personal Data collected through sources other than the User
The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
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Privacy Shield participation: data transfers from the EU and Switzerland to the United States
The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States.
The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise.
The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).
What does this mean for the European User?
The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.
This, most importantly, includes the right of individuals to access their personal data processed by the Owner.
The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.
The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Dispute resolution under the Privacy Shield
In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.
In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.
In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.
Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.
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Push notifications
This Application may send push notifications to the User.
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The Service is directed to children under the age of 13
This Application is directed to children under the age of 13. It doesn't require the child to disclose any more information than is reasonably necessary to participate in its activity.
Parents may review the personal information about their child collected by this Application - if any - outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Owner. Parents may also agree to the collection and use of their child’s information, but still not allow disclosure to third parties, unless disclosure is integral to the Service.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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User identification via a universally unique identifier (UUID)
This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Application, if not stated otherwise within this document.