Owner and Data Controller
MySmallWardrobe.com
Owner contact email: mysmallwardrobe@yahoo.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; email address; Data communicated while using the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Content commenting, Contacting the User, Analytics, Advertising, Commercial affiliation, Displaying content from external platforms, Hosting and backend infrastructure, Managing contacts and sending messages, Platform services and hosting, RSS feed management, Interaction with external social networks and platforms, Interaction with data collection platforms and other third parties and Interaction with live chat platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google AdSense (Google LLC)
Google AdSense is an advertising service provided by Google LLC. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Clickpoint (CLICKPOINT MARKETING SLU.)
Clickpoint is an advertising service provided by CLICKPOINT MARKETING SLU.
Personal Data processed: Tracker; Usage Data.
Place of processing: Spain – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
ClickWall (Click Wall Ltd.)
ClickWall is an advertising service provided by Click Wall Ltd.
Personal Data processed: Tracker; Usage Data.
Place of processing: Israel – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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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 Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
GameAnalytics (GameAnalytics ApS)
GameAnalytics is an analytics service provided by GameAnalytics ApS.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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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.
Amazon Affiliation (Amazon)
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
LinkShare (Rakuten Marketing LLC)
LinkShare is a commercial affiliation service provided by Rakuten Marketing LLC.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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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: email address; first name.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: email address.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
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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.
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, CPA and CTDPA
Disqus with advertising enabled (Disqus)
Disqus with advertising enabled is a hosted discussion board solution provided by Disqus that enables this Application to add a commenting feature to any content. Disqus and its third-party partners use Trackers in order to serve Users personalized ads. Users can opt out of such use of Trackers by visiting this opt-out page.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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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.
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google 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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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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.
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
Akamai Content Delivery Network (Akamai Technologies, Inc.)
Akamai is a hosting service provided by Akamai Technologies, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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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: email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
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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.
Google+ +1 button and social widgets (Google Inc.)
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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targeted advertising according to the CPA, CTDPA and UCPA
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA and VCDPA
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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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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, in order to contact and be contacted by this Application‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
ClickDesk Widget (ClickDesk Inc.)
The ClickDesk Widget is a service for interacting with the ClickDesk live chat platform provided by ClickDesk Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (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: email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA
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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.
Blogger (Google LLC)
Blogger is a platform provided by Google LLC 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.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
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a sale according to the CCPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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RSS feed management
This type of service allows this Application to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.
Feedburner (Google Inc.)
Feedburner is a service to manage RSS feeds provided by Google Inc. It allows the collection of statistics on what content is consumed and to insert ads in it.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet information.
This processing constitutes:
-
a sale according to the CCPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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ShopStyle Collective
Updated: [April 30, 2018]
This Privacy Policy describes how ShopStyle Inc. ("we," "us," "our," "Company") collect, use, share, and protect information in connection with the Company websites, mobile websites, mobile applications, browser applications, and any related services that refer or link to this Privacy Policy ("Services"). Company is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten, Inc., based in Tokyo, Japan.
1. COLLECTION OF INFORMATION.
User-provided information
We collect, process, and use your information when you:
Register for our Services or sign in to an existing account
Visit our website(s)
Access our Services through our application(s)
Connect to our Services using third-party accounts, such as your email, social media, or payment account(s)
Contact us for support
Participate in our shopping or influencer programs
Enter a sweepstakes, contest, promotion, survey, or poll
Automatically collected information
We and our service providers automatically collect certain information about you through:
Interaction with our Services
Cookies and other tracking technologies
Location-identifying technologies
Monitoring and analyzing trends, usage, and activities
The types of information you provide may include Personal Information. "Personal Information" means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:
First and last name
Email address
Mailing address
Phone number
Payment information (such as payment account name, payment account number, payment card expiration date, and billing address)
We may also collect Personal Information and other information based on your use of the Services:
The nature of the product or service requested or purchased
How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and information regarding the network and connected hardware (e.g., computer or mobile device)
Browsing, shopping, and purchase history
Your geolocation
Click-stream data (the page-by-page paths you take as you browse through our Services)
2. USE OF INFORMATION WE COLLECT. WE MAY USE INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:
Manage Your Account
If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.
Improve Our Services
We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.
Provide You Marketing Information
To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 4 (Your Choices) below.
Administer Contests, Sweepstakes, and Promotions
From time to time, Company may invite you to enter various contests, sweepstakes, surveys or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize.
3. SHARING OF INFORMATION.
We may share the information we collect, including your Personal Information, with third parties under the following circumstances.
Service Providers and Business Partner
We do not sell your Personal Information and only share it with third parties to operate our Services. We may share your Personal Information with our service providers that perform marketing services and other business operations on our behalf, under our instructions and in compliance with appropriate technical and organizational security measures to protect your data. For example, we may partner with other companies to provide you support services, authentication services, prevent fraud on our Services, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, facilitate your travel reservations, fulfill your product purchases, and administer your rewards or payments. We will not sell your Personal Information, but we may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates. Information that we may rent or sell will not include your Personal Information and will not include payment information.
Rakuten Group Companies
We work closely with our affiliated businesses and companies within the Rakuten Group and share your Personal Information for our internal business administration. We may also share your account credentials (username, email address, encrypted password) and related personal identification (first and last name and address) with other companies in the Rakuten Group, so that you will be able to use your username and password on other Rakuten websites and services. As long as you do not connect to another Rakuten service, your identifiers (username, email address, encrypted password, first name, last name, and address) are shared only with our parent company, Rakuten Inc., for the purposes of operating our authentication service. Information shared with Rakuten Inc. is subject to the Rakuten Privacy Policy. We may share your information with the Rakuten Group for internal business administration and to improve their websites, applications, marketing efforts, and products and services. The Rakuten Group will not sell your Personal Information, but may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates. Information that the Rakuten Group may rent or sell will not include your Personal Information and will not include payment information.
Protection of Rights and Other Legal Purposes
We may share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law; (ii) at the request of governmental authorities conducting an investigation, including, but not limited to, meeting law enforcement requirements; (iii) to defend our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of us or any third party.
Business Transfers
We may share the information we collect, including Personal Information, with any third party in connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure, or repossession), or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company.
4. YOUR CHOICES
You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing emails from us by using the unsubscribe link on the footer of our marketing emails, by logging into your account settings, or by using the Contact Us option through the Services. Upon written request, we will provide you with information on whether we hold any Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. You may at any time opt out from further allowing us to have access to your mobile location data by adjusting the permissions in your mobile device. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. We will respond to your requests within a reasonable timeframe.
5. RIGHTS APPLICABLE TO EU USERS
Data Transfers
If you are visiting from the European Union ("EU") or other regions with laws governing data collection and use that may differ from EU or United States law, please note that you may be transferring your Personal Information to the Rakuten Group in the United States and in other countries around the world for the purposes described under this Privacy Policy. We take great care in protecting your Personal Information and have put in place adequate mechanisms to protect it when it is transferred internationally. As part of the Rakuten Group, Company relies on the Rakuten Binding Corporate Rules to legitimize international data transfers within the Rakuten Group. The Rakuten Binding Corporate Rules have been approved with the Data Protection Authority of Luxembourg acting as the lead authority. You can learn more about this process and the way the Rakuten Binding Corporate Rules protect your data by visiting this page.
Legal basis for using your Personal Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:
Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
Consent. We will rely on your consent to use (i) technical information such as cookie data and geolocation data; and (ii) your Personal Information for marketing purposes. You may withdraw your consent at any time by contacting us using the information at the end of this Privacy Policy or by following an unsubscribe link in any marketing communication you receive from us.
Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
Choices under EU law
If your Personal Information is subject to the protections offered by EU law, you may:
Access, correct, update or request deletion of your Personal Information, at any time by contacting us using the contact details provided under the "Contact Us" section below;
Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information;
Withdraw your consent at any time if we have collected and process your Personal Information with your consent;
Complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including US and Canada) are available here.)
To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 14 below. Please note that if you are not subject to EU law, these rights do not apply to you.
6. DATA SECURITY AND RETENTION.
We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We use a secure, encrypted connection (using a TLS protocol) on all pages where you access or transmit Personal Information. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
7. PROMOTIONAL COMMUNICATIONS.
By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your Email Preferences in the Account Settings of your account; or (iii) contacting us through the Services. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.
8. COOKIES.
We and our partners use cookies and similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We use cookies for many purposes, including, without limitation, authentication, tracking user preferences or web pages visited while using our Services. You may control the use of cookies at the browser level. If you choose to disable cookies, it may limit your use of certain features or functions on the Service. For more information on how we use cookies and how you can manage them, please see our Cookie Policy.
9. ANALYTICS, TARGETING, TRACKING.
We, and third parties with which we partner, may also use cookies, pixels, and other technologies to automatically collect information about your use of the Services, such as your click-stream data, browsing history, IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected (also known as cross-linking). We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms. These third parties may also collect Personal Information about your online activities over time and across different websites when you use our Services to help predict your preferences and to display (and to enable other third parties to display) ads to be more likely to be of interest to you. Some third-party service providers that we engage (including third-party advertisers) may also place their own cookies on your browser. If you wish to opt-out of interest-based advertising click here (or if located in the European Union click here). Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.
10. THIRD-PARTY DATA.
The Services contain hyperlinks to websites of merchants and retailers and other websites or locations that we do not control and are operated and controlled by third parties ("Third-Party Websites"). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.
11. SOCIAL FEATURES.
Certain functionalities on the Services are specifically designed to permit interactions that you initiate between the Services and third-party websites or services, including third-party social networks ("Social Features"). Examples of Social Features include features that enable you to transmit your account content from a third-party website or service to our Services; to "like" or "share" our Services’ content on other websites or services; to sign in to the Services using your username and password from a third-party site or service; and to connect our Services with a third-party website or service. If you choose to use Social Features, the information you post or provide access to may be used by us and/or publicly displayed on our Services or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references our Services (e.g., by using a hashtag associated with Company in a tweet or status update), your post may be published on our Services in accordance with the terms of the third-party website or service. When you use our Services with a third-party site or service, both Company and the third party may have access to certain information about you and your use of our Services and the third-party site or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their "connections," or information about you is otherwise accessible through your connections’ web pages, profile pages, or similar pages on a social-networking or other third-party website or interactive service. The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy policies, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third party websites or services.
12. REFERRAL PROGRAMS.
Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of sending this communication to invite them to join the Services. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at hi@shopstyle.com.
13. CHANGES TO PRIVACY POLICY.
This Privacy Policy is current as of the date set forth above. Company reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and where such changes will impact you as a data subject, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).
14. CONTACT US.
If you have any questions regarding this Privacy Policy, please feel free to contact us by email at legal@shopstyle.com or by mail at 800 Concar Drive, Suite 175, San Mateo, CA 94402, ATTN: ShopStyle Legal.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
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Rewardstyle
Introduction
This Privacy Policy and our Cookie Policy apply to your use of our Services.
Services
This Privacy Policy ("Policy") covers how rewardStyle, Inc. ("rewardStyle", “rS”, “us” or “we”) treats personal information that it receives, tracks or collects in connection with an Influencer’s use of online websites at https://www.liketoknow.it and https://www.rewardStyle.com ("Sites") and any applications, such as Like to Know It ("Apps") (collectively, the "Services").
Influencers use our Services to monetize their content.
Our Services create technological and commercial relationships between third-party retailers, advertisers and other businesses ("Merchants"), individuals and entities with websites, blogs, social media presence, agents or agencies, digital publishers and other content platforms ("Influencers", “You”, or “Your”) and consumers ("Consumers"). Our Services allow You to monetize your content and earn commissions, by facilitating sales (“Sales”) and marketing of Merchant products and services (collectively, "Products") and creating a convenient shopping experience to Consumers.
This Policy tells you, among other things, what information we gather from you when you visit our Sites or Apps, through our Services, how we may use or disclose that information, how to review or edit it, and our efforts to protect it.
Please read this Policy carefully. By registering for, accessing, using, and/or downloading any Services, you agree to this Policy. Among other things, you consent to the collection, tracking and use of your personal information as outlined in this Policy, as such Policy may be amended from time to time.
Changes
Changes to the Privacy Policy apply to your use of our Services after the effective date of the policy.
rewardStyle may change this Policy or any other terms, at any time. rewardStyle will notify You of a change through our Services, such as when You next log-in, or by other means. The new terms may be displayed on-screen and You may be required to read and accept them to continue Your use of the Apps or Sites. rewardStyle will also post the terms at https://www.rewardStyle.com and they are effective immediately upon posting. If You choose not to accept any new terms, You may close your account and/or discontinue using our Services. You acknowledge that continued use of our Services after we post or send notice of the changes means that your personal data is subject to the updated Privacy Policy.
1. Information We Collect or Track.
We may collect or track the following information:
Application Information. We collect the data that you provide to us to apply to the platform.
When you apply for an invitation, you are required to give certain information, such as your name, email address, blog or other content platform name, blog or other content platform address, region of influence, content categories, social follower and referrer information.
Registration Information. We collect the data that you provide to us to register your account.
If you receive and accept our invitation, we will request certain information from you, including your contact information (such as name, address, and phone number), social media handles, company name, social security number and/or tax identification number and/or national ID, financial information (such as bank account information, PayPal account information, AliPay account information), agency contact, contributors, date of birth, gender, preferred name, and information for booking travel.
Interaction With Services and Access. We collect data when you interact with and use our Services and when you share information from the Services with others.
We gather certain information automatically when you interact with the Services, including data relating to Sales. We may also collect information from the mobile phone, tablet, computer or other device that you use to access the Services. This information may include your domain and/or Internet Protocol ("IP") addresses, browser type, Internet Service Provider ("ISP"), the referring or exiting website address, operating system, access times and history, information relating to your activities and preferences on the Services, device, unique device identifiers, mobile platform advertising identifiers (e.g., IFA/IDFA or Android ID), telephone number, mobile carrier, language, CPU, iOS, screen, display, plug-ins, Mime, font, storage, time, canvas, currency, images or other posted content, downloaded content, favorited products and folders, communications on the Services with other users, posts in public forums, and information from cookies or other technology. See below for more information about Cookies.
We may also infer location from IP addresses or other information, for example, Wi-Fi access points and mobile towers. Among other things, this information allows the creation of device fingerprints and profiles about the possible relationships among different browsers and devices.
We also collect data on your sales, commissions, clicks generated by Consumers and sales generated by Consumers.
Collaboration Data. If you engage in collaborations, then we collect related data including the brand/retailer, fulfillment and earnings information.
Additional Consumer Data. We collect information from Consumers who engage with your content in order to track sales and facilitate commissions.
We collect and track data over time and across websites and/or apps from visitors to Influencers’ sites. For example, we collect and track data on consumers who click on a Merchant link or other links. We also collect visitors’ IP addresses and may infer location from IP addresses. Among other things, this information allows us to facilitate commissions and generate reports for Influencers and Merchants. We also track device information from visitors to an Influencer’s site, which includes data points on browsers, operating systems, device type, CPU, mobile, iOS, screen, display, plug-ins, Mime, font, storage, time, language and canvas. Among other things, this information may allow us to create profiles about the possible relationships among different browsers and devices. We also collect data on traffic, impressions, views and clicks.
Marketing Campaign. If you engage in marketing campaigns, then we collect related data including title, date, rate and clicks information.
Direct Marketing and Do Not Track Signals. We currently do not share personal data with third parties for their direct marketing purposes without your permission. WE DO NOT RESPOND TO "DO NOT TRACK" SIGNALS.
Correspondence. If you send us personal correspondence, such as an email or letter, we may collect such information into a file specific to you.
Third Party Referral. We may collect certain information regarding you when a third party voluntarily provides such information, such as when using the "Invite Now" option with respect to our communications.
Public/Sponsored Events. rS may participate in public events and events with multiple sponsors, such as trade shows and seminars. The events generally collect certain information from all attendees and distribute this data in whole or in part to all the event sponsors including rS. We do not control and are not responsible for the practices of other sponsors for these events.
Social Network Sites (“SNS”). If you signed up for our Services in connection with an SNS, then we may have collected information from SNS used in connection with the Services, such as name, gender, date of birth, geo-location, interests, when you "Like" or click links provided by or through the Apps and other information available through your SNS page. It is your responsibility to read and accept the relevant terms of service and privacy policy associated with the
particular SNS service. We may have also collected information regarding Likes, Views and other engagement data.
Geo-location, Contacts and Camera Roll. We collect information from Consumers who engage with your content in order to track sales and facilitate commissions.
With your permission, we may also access (1) your geo-location through GPS tracking, (2) contacts, and (3) your camera roll or saved images.
Push Notifications. With your permission, we will send push notifications. Visit your settings to control.
With your permission, we may send you push notifications and may track and collect information about your interaction with such notifications.
Information Collected, Tracked or Analyzed by Third Parties. We collect data through cookies, other tracking technologies and by using third party analytics. Links to these third parties’ privacy policies are provided in this section. See below for more information about Cookies.
We may permit advertisers or other third parties to collect information from the Services. For example, a third party may place cookies or similar tracking technologies (such as advertising IDs or deep linking technology) and may send its own cookies to your cookie file. We may also utilize third parties to analyze data collected from the Services. We may permit third parties to collect personally identifiable information over time and across different websites and across multiple mobile apps. Please see the following third party privacy policies for additional information: https://www.usebutton.com/privacy-policy, https://amplitude.com/privacy, https://branch.io/policies/#privacy, https://later.com/privacy/, https://mailchimp.com/legal/privacy/, https://www.surveymonkey.com/mp/legal/privacy-policy/, https://www.sparkpost.com/policies/privacy/, https://splashthat.com/privacy and https://support.google.com/analytics/answer/6004245?hl=en.
2. How We Use Collected/Tracked Information.
We use your data to provide, develop, support, customize, market and protect our Services and pay commissions.
We use the information we collect or track about you to:
Assess your website, platform and/or content suitability;
Pay you the commissions you earn, including providing data to payment processors like PayPal and AliPay and addressing tax issues;
Operate, maintain, and provide to you the services, features and functionality of the Services;
Help you quickly find information and prevent you from having to enter information more than once;
Improve the quality and design of the Services;
Provide customized content and services, including without limitation potential collaborations, advertising and promotional information, such as targeted ads / retargeted ads, recommend content you might like, and cross-app / cross-site functionality across multiple third party mobile apps and websites;
Market and promote our Services to you and others;
Diagnose problems with the Services;
Create new features, functionality, and services;
Communicate with you, including sending you emails regarding products or services that you have liked;
Provide customer support;
Provide reports and other data to Merchants that may identify you and include data about your performance, your sites and aggregated consumer data;
Create device fingerprints and profiles about the possible relationships among different browsers and devices;
Creation of consumer profiles, which may combine Your personal information from one rewardStyle service with personal information and other data from other rewardStyle services or rewardStyle partners;
Facilitate use of the Services, including indexing your name and relevant business information to make it available to other rS users;
Perform research and analysis on your use of the Services;
Manage your account;
Protect the security and integrity of the Services, as well as the property, rights and personal safety of rS, our users or others; and
Enforce the Terms of Service, this Policy and any other agreements you have entered into with rS.
3. Information We Share With Others.
Information from the Services, including Consumer Data. We share collected data across our Services and certain information with Merchants, Influencers and API Developers. We may also share with other service providers, for example to assist us with data analytics for development of new and better services.
We may provide information about you and your business, including aggregated consumer data, to our affiliates and other businesses or individuals, including our Merchants, Influencers and API Developers. We share anonymized consumer geo-location, purchased item and amount of sale data with Merchants and Influencers. We may combine information internally across different Services so that we may provide better and more customized services. We contract with companies who help with parts of our operations and/or to enhance our services and we require them to only use your personal information in connection with the services they perform. We may also share aggregated non-personally identifiable information publicly.
Please see the following third party privacy policies for additional information: https://www.usebutton.com/privacy-policy, https://amplitude.com/privacy, https://branch.io/policies/#privacy, https://later.com/privacy/, https://mailchimp.com/legal/privacy/, https://www.surveymonkey.com/mp/legal/privacy-policy/, https://www.sparkpost.com/policies/privacy/, https://splashthat.com/privacy and https://support.google.com/analytics/answer/6004245?hl=en.
Legal Compliance. We may share your data if required or necessary by law. We may also do so to exercise, defend or protect our, your or others’ rights.
rewardStyle will cooperate with law enforcement inquiries, other government agency inquiries and requests, and criminal or civil subpoenas. rewardStyle will also disclose your personal information when necessary to comply with state and federal laws and regulations. rewardStyle may also disclose information to exercise or defend our legal rights, to protect the security of our Services and business, to investigate and prevent illegal or tortious activity, to protect the property or safety of rewardStyle or others, and to enforce rewardStyle agreements or other policies.
Sale or Other Transfer. We may share your data when some or all of our business is sold, acquired or merged with another company.
As we develop our business, we may buy or sell some or all of our assets and, depending on the transaction, your personal information may be one of the transferred assets. Similarly, if rewardStyle should ever merge with or be acquired by another company, we may share your personal information with any entity resulting from such transaction. Any entity that acquires your data in this manner will have the right to use your data as set forth in this Policy. Separately, if rewardStyle should ever file for bankruptcy, the bankruptcy trustee has the right to sell the information you provide to us to a third party.
Disclaimer. We cannot guarantee the security of your data. Please see the measures we take Security below.
We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Policy. By way of example (without limiting the foregoing), we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmission of private communications, or users may abuse or misuse your personal information that they collect from the Services
4. Your California Privacy Rights.
If you are a California resident, then you may have certain rights relating to whether any third parties have received your information for their direct marketing purposes.
For California residents: Under California Civil Code Section 1798.83, if you are a California resident and rewardStyle has an established business relationship with you, you may have the right to request information from rewardStyle, free of charge, regarding the manner in which rewardStyle shares certain categories of personal information with third parties for their direct marketing purposes (if any). Alternatively, at our election, rewardStyle may provide you with a cost-free means to choose not to have your information shared.
rewardStyle's designated email address for such requests is legal@rewardstyle.com. You may also request this information by writing to:
ATTN: Legal
3102 Oak Lawn Avenue
Suite 900
Dallas, TX 75219
5. Cookies / Tracking Technologies.
We collect data through cookies and other tracking technologies. For more information about cookies, see our Cookie Policy.
We may use cookies, pixels, scripts, etags, advertising IDs, IFA/IDFA, log files, clear gifs, web beacons, deep linking or other technology. We may use these technologies in a variety of ways, including but not limited to:
Tracking Sales to Consumers;
Facilitating Commissions to Influencers;
Creation of user profiles;
Providing custom, personalized content and information to Influencers and Consumers including without limitation relevant ads, customized ads, interest-based ads and retargeted ads in future navigation;
Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Services;
Providing cross-app / cross-site functionality across multiple third party mobile apps and websites;
Collect device information which permits generation of device fingerprints and cross-device consumer profiles;
Keeping count of return visits to our Services and Influencers’ sites;
Accumulating and reporting statistical information on Services usage and Influencers’ sites, platform and content;
Determining which features users like best;
Assessing the popularity and effectiveness of the Services;
Determining whether and when an email was opened; and
Improving our Services and creating new services.
You can refuse cookies by turning them off in your browser. However, if you turn off cookies, then you may not be able to utilize certain features of the Services. Turning off and/or deleting cookies does not affect other tracking technologies, such as device fingerprinting.
This Privacy Policy covers the use of cookies and other tracking technologies by these Services only.
rS or an affiliate network (each an "Affiliate Network Partner") may drop cookies on a consumer’s device and/or web browser. For example, once an Influencer grabs a Product or Merchant link from our Services, visitors to that Influencer’s website who click on the particular link will be directed by rS or the Affiliate Network Partner to a Merchant’s e-commerce site, at which point rS or the Affiliate Network Partner drops a cookie on the visitor’s browser. These cookies are dropped so that our Services can monetize visits to our Influencers and other actions.
rewardStyle may also utilize third party tracking technology, such as deep linking, to leverage cross-app and cross-site functionality.
Another tracking technology is a script that collects device information to permit what is known as device fingerprinting. (see, e.g., FTC Consumer Guide on Online Tracking - What is device fingerprinting?) For example, this data collection may permit generation of device fingerprints and cross-device profiles to better understand who visits particular Influencers, how often, unique visits, repeat visits, and more.
You agree rS is not liable for the content or use of personal information by third parties, including, without limitation, SNS, Influencers and Merchants, and including their use of cookies and other tracking technologies. Users and Consumers should consult the privacy policies and terms of service for those individual websites.
By agreeing to the terms of this Policy and by using our Services, you consent to the cookies and other tracking technologies referenced above. It is your responsibility to inform your visitors of the relevant data collection, use and disclosure practices through a privacy policy – see Section 8. In order for you to be a registered and active user of the Services, you must agree to accept cookies and other tracking technologies and to post a privacy policy. If you wish to opt-out of cookies and other tracking technologies altogether, send an email info@rewardstyle.com to request your account be deleted.
6. Influencers’ Websites/Applications/Other Content.
General. When you begin using links, scripts, cookies and other technologies provided by rS, we will collect and store information about your users and readers. We use this information for tracking sales, abuse prevention, commission processing and data analysis, among other things.
Requirement of Privacy Policy. Influencers are solely responsible for ensuring that their own website, application or other content take all necessary and proper measures to protect personal privacy, including following a written Privacy Policy posted on such sites, and adhering to all appropriate regulations, laws and other requirements. You must include in your disclosures all the information related to consumer data collection practices, a link to FTC Consumer Guide on
Online Tracking, and a link to this rewardStyle Privacy Policy and any other applicable policies for rewardStyle Services.
Promotion and Publicity. We may collect and store information about publicly accessible content on your website, application or other content (such as your website name and website content). Among other things, we may use this information to recommend certain Merchants and for advertising and marketing related activities.
7. Links to Other Sites, Networks, Platforms, and Apps.
You may encounter Linked Technologies that have their own privacy policies.
The Services may contain links to third party sites, networks – including social network sites like Instagram, Snapchat, Facebook, Twitter, Pinterest or others, platforms or apps ("Linked Technologies"), including retailers and advertisers. However, please be aware that rewardStyle is not responsible for and cannot control the terms of service or privacy policies of such other Linked Technologies. We encourage you to be aware when you leave the Services, and to read the applicable agreements and privacy policies for each and every Linked Technologies. The Agreement applies solely to these Services. rewardStyle is not responsible for and makes no representations or warranties regarding Linked Technologies, including without limitation, the content, accuracy, opinions, functionality, or services provided in such Linked Technologies. Inclusion of any Linked Technologies on the Services does not imply approval or endorsement by rewardStyle. If You decide to access any Linked Technologies, then You do so at your own risk.
8. Third-Party Applications.
rS may, in its sole discretion, provide Influencers with access to third-party Developer Apps which interface with rS APIs. Such Developer Apps use rS APIs, but are not endorsed by rS. Use of such Developer Apps by Influencers is voluntary and subject to the election by the Influencer, in its sole discretion, to use any Developer Apps. Use at your own risk. By using Developer Apps, you are granting Developer Apps access rights to your Content, including without limitation related metadata. rS makes no representations or warranties regarding Influencers’ use of any Developer Apps, or the privacy or security of data or information provided to third parties or their Developer Apps. You agree rS has no liability whatsoever for the Developer Apps, including, without limitation, the third party use of personal information provided to third parties or through Developer Apps, nor the use of cookies or other tracking technologies by third parties or Developer Apps. Influencers using Developer Apps should consult the privacy policies and terms of service for those individual Developer Apps.
9. Age Restrictions; Children’s Privacy.
Our Services are not for use of anyone under the age of 13.
These Services are not for use for anybody under the age of 13. By using these Services, you verify that you are 13 or older and in compliance with this provision. rS will not knowingly collect or use personal information from anyone under 13 years of age. If rS obtains actual knowledge that it has obtained personal information about a child under the age of 13, that information will be permanently deleted from our records.
10. Choice/ Opt Out.
You have choices about how your data is collected, the ability to delete certain data, and the ability to close your account.
Cookies. You may be able to delete and/or turn off cookies as your browser or device permits. Unless you block or control cookies going forward, deleting cookies will only address cookies on your device at that moment. If you disable cookies entirely, rewardStyle Services may not function properly. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off or deleting cookies.
Flash Cookies. Some newer versions of browsers will let you control and/or delete Flash cookies. If you use a browser or device that does not let you delete Flash cookies, then try Adobe's Website Storage Settings. Similar to regular cookies, deleting Flash cookies will only address the Flash cookies on your device at that moment. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off or deleting Flash cookies.
Other Tracking Technologies. You may be able to turn off and/or delete some scripting functionality as your browser or device permits. If you disable scripting functionality, rewardStyle Services may not function properly. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off some script functionality.
Opting Out from Interest-Based Ads: US residents may visit www.aboutads.info/choices to opt out of interest-based advertising by companies participating in the DAA self-regulatory program and European Union residents may opt-out of interest-based advertising by companies participating in the EDAA at www.youronlinechoices.com. Your browser must accept third-party cookies before opting out. You can also express your choices through the following platforms: IAB opt-out platform, Network Advertising Initiative opt-out platform, Digital Advertising Alliance platform that provide options to express your choices for all companies that are registered in this platform. Please note that if you disable the display of personalized ads from rewardStyle and other advertising partners, you will continue to receive ads that are less relevant to your interests/browsing behavior.
Opting Out for Application Data: To opt out of interest-based advertising on mobile apps, US residents may download the DAA's AppChoices application from the Android or Apple app store.
Opting Out for Location Data: You may opt out of precise location data by using the location services controls in your mobile device's settings. Please note that this does not impact geolocation inferences, which may be possible through IP address information.
Opting out of push / local notifications: We may send push or local notifications to your device to provide updates and relevant messages. You may be able to manage notifications from the Sites, Apps or through your device.
Effect of Opting Out: You will need to renew your opt-out choice if you use a different device, use a different browser, or erase cookies from your browser.
Unsubscribing from emails: You may opt out at any time by using the Opt-Out or Unsubscribe option at the bottom of most of our mass email communications, or by contacting us through the "Contact Us" section of the Services.
Account: You may also choose to close your account at any time.
11. Security.
Although we work to protect your data, we cannot warrant or ensure its ultimate security.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before creating your account. The user who created the account is responsible for maintaining the secrecy of their unique password and account information at all times.
Payment processing will be performed by a third party vendors, such as PayPal or Alipay, which have their own security policies that relate to the data they process. For information about PayPal's User Agreement and Privacy Policy, please visit https://www.paypal.com/us/webapps/mpp/ua/useragreement-full and https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
We use what we believe to be appropriate procedures to protect information against unauthorized access and disclosure. However, information you elect to post on our Services, emails and other information you send to us are not encrypted and such transmissions cannot be considered a secure means of transmitting sensitive information.
You should be aware of the limitations of security, authentication, encryption, and privacy measures used in connection with the Internet and that any information you transmit through the Services may be damaged, corrupted, "sniffed" and/or accessed by another person without your permission. Regardless of the precautions taken by you or by us, "perfect security" does not exist on the Internet. Third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the Services. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. We cannot ensure or warrant the ultimate security of any information you transmit.
12. File a Complaint.
If for some reason you believe rS has not adhered to the principles of this Policy, please notify us at legal@rewardstyle.com. For those in the EU / EEA, send complaints or questions to datarequests@rewardstyle.com.
13. Users in the European Union and European Economic Area.
If you are in the EU / EEA, then this section applies to you.
Personal Data
Personal Data is any information relating to an identified or identifiable natural person in the European Union (“EU”) and European Economic Area (“EEA”).
Data Controller
LTK is the data controller of Personal Data you provide on our Services (within our Apps or on our Sites).
You may contact LTK via email at datarequests@rewardstyle.com or by mail at:
rewardStyle
3102 Oak Lawn Avenue
Suite 900
Dallas, TX 75219
ATTN: Data Request
Purposes of Processing and Legal Basis for Processing
We have lawful bases to collect, use and share your data.
As explained above, we process Personal Data in various ways depending upon your use of our Services. We process Personal Data on the following bases: (1) with your consent; (2) as necessary to perform a contract when you request Services; and (3) as necessary for our legitimate interests in providing you with our products and Services, enhancing and customizing our Services, conducting analytics and delivering relevant advertising as set forth above.
Your Rights Regarding Personal Data
If you are in the EU / EEA, then you have certain rights relating to your personal data.
Access and Confirmation. You have the right to ask us if we process Personal Data about you, and in some circumstances, to obtain a copy of your Personal Data.
Deletion and Blocking. Under certain circumstances, you may have the right to have your Personal Data deleted or blocked without undue delay.
Direct Marketing. You have the right to object to our processing of Personal Data for direct marketing purposes.
Consent. To the extent we are processing Personal Data on the basis of your consent, you have the right to withdraw consent at any time.
Data Portability. Under certain circumstances, to the extent we are processing your Personal Data on the basis of consent, or that it is necessary to perform a contract with you, and the processing is carried out by automated means, you have the right to receive the Personal Data in a structured, commonly used and machine-readable format.
To exercise those rights, please contact us at:
3102 Oak Lawn Avenue
Suite 900
Dallas, TX 75219
Email: datarequests@rewardstyle.com
Right to Lodge a Complaint. You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country.
Transfers
We transfer, store, and process your data outside your country.
We are headquartered in the United States of America. Personal Data may be accessed by us or transferred to us in the United States. The European Commission has not determined that the United States ensures an adequate level of protection for Personal Data. By providing us with Personal Data, you consent to this transfer. We will protect the privacy and security of Personal Data according to this Privacy Policy, regardless of where it is processed or stored.
By providing us with Personal Data, you consent to the storage or processing of Personal Data in the United States and acknowledge that the Personal Data will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Data.
14. Retention of Personal Data.
The Personal Data we obtain about you may be retained up to seven years.
15. Contact Us.
You can contact us for complaints or questions.
Any notices or communication sent to you by rS will be sent to your email address on file with rS, which may be updated by you in writing at any time. It is your responsibility for ensuring that rS has your current email address at all times. Any notice sent to you via such email address by rS shall be deemed given, received, and read by you, whether or not it actually is received and/or read.
Any notices or communications sent by you to rS pursuant to this Policy must be in writing and sent to the address specified herein or such other address as rS may specify in writing.
All notices will be sent to: rewardStyle.com
3102 Oak Lawn Avenue
Suite 900
Dallas, TX 75219
Email: legal@rewardstyle.com
ATTN: Legal
For those in the EU / EEA, send complaints or questions to datarequests@rewardstyle.com.
Effective date: May 23, 2018
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Futher information for California consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers and internet information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CTDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the UCPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
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 statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.