Privacy Policy of Calocurb Wholesale

Welcome to the privacy policy of Calocurb Wholesale. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.

Latest update: February 09, 2025

Summary

Data we collect automatically

We automatically collect data from you for example when you visit Calocurb Wholesale.

  • Trackers
  • Usage Data
  • device information
  • number of Users
  • +28

Trusted third parties help us to process it

How we use them

  • Advertising
  • Tag Management
  • Displaying content from external platforms
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
  • Analytics
  • Traffic optimization and distribution
  • User database management
  • Spam and bots protection
  • Managing data collection and online surveys
  • Interaction with data collection platforms and other third parties
  • Interaction with online survey platforms
  • Heat mapping and session recording

Data you give to us

We collect the data you give to us for example when you sign up for our newsletter.

  • first name
  • last name
  • phone number
  • email address
  • +20

Trusted third parties help us to process it

How we use them

  • Contacting the User
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
  • User database management
  • Spam and bots protection
  • Managing data collection and online surveys
  • Interaction with data collection platforms and other third parties
  • Interaction with online survey platforms

Owner and Data Controller

Calocurb USA Limited
8 The Green, Suite A
Dover, Delaware 19901
USA

Owner contact email: digital@calocurb.com

Type of Data we collect

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

  • Trackers
  • Usage Data
  • first name
  • last name
  • phone number
  • email address
  • payment info
  • purchase history
  • billing address
  • shipping address
  • gender
  • date of birth
  • physical address
  • company name
  • profession
  • country
  • state
  • username
  • various types of Data
  • device information
  • password
  • number of Users
  • session statistics
  • city
  • ZIP/Postal code
  • province
  • county
  • latitude (of city)
  • longitude (of city)
  • metro area
  • geography/region
  • IP address
  • app information
  • device logs
  • operating systems
  • browser information
  • language
  • launches
  • number of sessions
  • session duration
  • scroll-to-page interactions
  • mouse movements
  • scroll position
  • keypress events
  • motion sensor events
  • touch events
  • video views
  • clicks
  • browsing history
  • search history
  • page views
  • interaction events
  • page events
  • custom events
  • Application opens
  • 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:

  • Advertising
  • Tag Management
  • Displaying content from external platforms
  • Contacting the User
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
  • Analytics
  • Traffic optimization and distribution
  • User database management
  • Spam and bots protection
  • Managing data collection and online surveys
  • Interaction with data collection platforms and other third parties
  • Interaction with online survey platforms
  • Heat mapping and session recording

Detailed information on the processing of Personal Data

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 for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Google LLC

Google Ads conversion tracking

Company: Google LLC

Place of processing: United States

Personal Data processed: Trackers +1

Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California
Meta Platforms, Inc.

Meta ads conversion tracking (Meta pixel)

Company: Meta Platforms, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California
LinkedIn Corporation

LinkedIn Ads

Company: LinkedIn Corporation

Place of processing: United States

Personal Data processed: Trackers +1

LinkedIn Ads is an advertising service provided by LinkedIn Corporation.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in the United States
  • a Sharing in California
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana
LinkedIn Corporation

LinkedIn conversion tracking (LinkedIn Insight Tag)

Company: LinkedIn Corporation

Place of processing: United States

Personal Data processed: device information +2

LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Application.

Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.

Personal Data processed:
  • device information
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
Hotjar Ltd.

Hotjar Form Analysis and Conversion Funnels

Company: Hotjar Ltd.

Place of processing: Malta

Personal Data processed: Trackers +1

Hotjar is an analytics service provided by Hotjar Ltd. Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information

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.

Meta Platforms, Inc.

Meta Events Manager

Company: Meta Platforms, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California
HubSpot, Inc.

HubSpot Analytics

Company: HubSpot, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

HubSpot Analytics is an analytics service provided by HubSpot, Inc.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in the United States
Google LLC

Google Analytics 4

Company: Google LLC

Place of processing: United States

Personal Data processed: number of Users +3

Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

In order to understand Google's use of Data, consult their partner policy and their Business Data page.

Personal Data processed:
  • number of Users
  • session statistics
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information

Contacting the User

this Application

Contact form

Company: this Application

Personal Data processed: email address +3

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

Personal Data processed:
  • email address
  • first name
  • last name
  • phone number
Service provided by:
  • this Application
Category of Personal Information collected according to the CCPA
  • identifiers
This processing constitutes:
  • a Sale in California

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google LLC

Google Fonts

Company: Google LLC

Place of processing: United States

Personal Data processed: Trackers +1

Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California
Fonticons, Inc.

Font Awesome

Company: Fonticons, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

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:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California
Google LLC

YouTube video widget

Company: Google LLC

Place of processing: United States

Personal Data processed: Trackers +1

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

Personal Data processed:
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in California

Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Google LLC

Google Pay

Company: Google LLC

Place of processing: United States

Personal Data processed: billing address +10

Google Pay is a payment service provided by Google LLC, which allows users to make online payments using their Google credentials.

Personal Data processed:
  • billing address
  • email address
  • first name
  • last name
  • payment info
  • phone number
  • purchase history
  • shipping address
  • Trackers
  • Usage Data
  • various types of Data as specified in the privacy policy of the service
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • commercial information
  • internet or other electronic network activity information
PayPal Inc.

PayPal

Company: PayPal Inc.

Place of processing: See the PayPal privacy policy

Personal Data processed: billing address +12

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

Personal Data processed:
  • billing address
  • device information
  • email address
  • first name
  • last name
  • password
  • payment info
  • phone number
  • purchase history
  • Trackers
  • Usage Data
  • username
  • various types of Data as specified in the privacy policy of the service
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • commercial information
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana
PayPal Inc.

Venmo Business

Company: PayPal Inc.

Place of processing: United States

Personal Data processed: billing address +8

Venmo Business is a payment service provided by PayPal Inc, which allows Users to make payments using their mobile phones.

Personal Data processed:
  • billing address
  • email address
  • first name
  • last name
  • payment info
  • phone number
  • purchase history
  • shipping address
  • Trackers
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • commercial information
  • internet or other electronic network activity information
This processing constitutes:
  • a Sale in the United States
  • a Sharing in California
  • Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana

Heat mapping and session recording

Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior. Some of these services may record sessions and make them available for later visual playback.

Hotjar Ltd.

Hotjar Heat Maps and Recordings

Company: Hotjar Ltd.

Place of processing: Malta

Personal Data processed: Trackers +2

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd. Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed:
  • Trackers
  • Usage Data
  • various types of Data as specified in the privacy policy of the service
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information

Interaction with data collection platforms and other third parties

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

Hotjar Ltd.

Hotjar Recruit User Testers

Company: Hotjar Ltd.

Place of processing: Malta

Personal Data processed: Trackers +2

The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd. Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed:
  • Trackers
  • Usage Data
  • various types of Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information

Interaction with online survey platforms

This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Hotjar Ltd.

Hotjar Poll & Survey widgets

Company: Hotjar Ltd.

Place of processing: Malta

Personal Data processed: Trackers +2

The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd. Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed:
  • Trackers
  • Usage Data
  • various types of Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information

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.

Klaviyo Inc.

Klaviyo

Company: Klaviyo Inc.

Place of processing: United States

Personal Data processed: company name +15

Klaviyo is an email address management and message sending service provided by Klaviyo Inc.

To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

Personal Data processed:
  • company name
  • country
  • date of birth
  • email address
  • first name
  • gender
  • last name
  • phone number
  • physical address
  • profession
  • purchase history
  • state
  • Trackers
  • Usage Data
  • username
  • various types of Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • commercial information
  • internet or other electronic network activity information
  • employment related information
This processing constitutes:
  • a Sale in California
  • a Sharing in California
Mailgun Technologies, Inc.

Mailgun

Company: Mailgun Technologies, Inc.

Place of processing: United States

Personal Data processed: country +11

Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.

Personal Data processed:
  • country
  • date of birth
  • email address
  • first name
  • gender
  • last name
  • phone number
  • physical address
  • profession
  • Trackers
  • Usage Data
  • various types of Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information
  • employment related information
This processing constitutes:
  • a Sale in California
  • a Sharing in California

Managing data collection and online surveys

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

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

Hotjar Ltd.

Hotjar surveys

Company: Hotjar Ltd.

Place of processing: Malta

Personal Data processed: Data communicated while using the service +2

Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd. Hotjar surveys may use cookies to track User behavior. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.

Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.

Personal Data processed:
  • Data communicated while using the service
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information

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.

Shopify Inc.

Shopify

Company: Shopify Inc.

Place of processing: Canada

Personal Data processed: billing address +9

Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.

Personal Data processed:
  • billing address
  • device information
  • email address
  • first name
  • last name
  • payment info
  • phone number
  • shipping address
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • commercial information
  • internet or other electronic network activity information

Spam and bots protection

This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.

Cloudflare, Inc.

Cloudflare Bot Management

Company: Cloudflare, Inc.

Place of processing: United States

Personal Data processed: app information +37

Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.

Personal Data processed:
  • app information
  • Application opens
  • browser information
  • browsing history
  • city
  • clicks
  • country
  • county
  • custom events
  • device information
  • device logs
  • geography/region
  • interaction events
  • IP address
  • keypress events
  • language
  • latitude (of city)
  • launches
  • longitude (of city)
  • metro area
  • motion sensor events
  • mouse movements
  • number of sessions
  • operating systems
  • page events
  • page views
  • province
  • scroll position
  • scroll-to-page interactions
  • search history
  • session duration
  • session statistics
  • state
  • touch events
  • Trackers
  • Usage Data
  • video views
  • ZIP/Postal code
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information
  • geolocation data
  • inferences drawn from other personal information

Tag Management

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

Google Ireland Limited

Google Tag Manager

Company: Google Ireland Limited

Place of processing: Ireland

Personal Data processed: Trackers

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed:
  • Trackers
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information

Traffic optimization and distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Prospect One Sp. z o.o. sp. k.

jsDelivr CDN

Company: Prospect One Sp. z o.o. sp. k.

Place of processing: Poland

Personal Data processed: Usage Data

jsDelivr CDN is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.

Personal Data processed:
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • internet or other electronic network activity information
Cloudflare, Inc.

Cloudflare

Company: Cloudflare, Inc.

Place of processing: United States

Personal Data processed: Trackers +1

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.

Personal Data processed:
  • Trackers
  • various types of Data as specified in the privacy policy of the service
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

HubSpot, Inc.

HubSpot CRM

Company: HubSpot, Inc.

Place of processing: United States

Personal Data processed: email address +4

HubSpot CRM is a User database management service provided by HubSpot, Inc.

Personal Data processed:
  • email address
  • first name
  • last name
  • Trackers
  • Usage Data
Service provided by:
Category of Personal Information collected according to the CCPA
  • identifiers
  • internet or other electronic network activity information

Further Information for Users in the European Union

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

Legal basis of processing

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

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

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

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

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

The rights of Users based on the General Data Protection Regulation (GDPR)

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

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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

Details about the right to object to processing

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

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Internet or other electronic network activity information

Sold or Shared

Targeted Advertising

Personal Data processed: Trackers; Usage data; Various types of data as specified in the privacy policy of the service; First name + 50

Personal Information collected or disclosed:
  • Trackers
  • Usage Data
  • various types of Data as specified in the privacy policy of the service
  • first name
  • last name
  • phone number
  • email address
  • purchase history
  • billing address
  • shipping address
  • gender
  • date of birth
  • physical address
  • company name
  • profession
  • country
  • state
  • various types of Data
  • device information
  • number of Users
  • session statistics
  • city
  • ZIP/Postal code
  • province
  • county
  • latitude (of city)
  • longitude (of city)
  • metro area
  • geography/region
  • IP address
  • app information
  • device logs
  • operating systems
  • browser information
  • language
  • launches
  • number of sessions
  • session duration
  • scroll-to-page interactions
  • mouse movements
  • scroll position
  • keypress events
  • motion sensor events
  • touch events
  • video views
  • clicks
  • browsing history
  • search history
  • page views
  • interaction events
  • page events
  • custom events
  • Application opens
  • Data communicated while using the service
Sensitive Personal Information collected or disclosed

payment info, username, password

Purposes:
  • Advertising
  • Tag Management
  • Displaying content from external platforms
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
  • Analytics
  • Traffic optimization and distribution
  • User database management
  • Spam and bots protection
  • Managing data collection and online surveys
  • Interaction with data collection platforms and other third parties
  • Interaction with online survey platforms
  • Heat mapping and session recording
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Google LLC, Google Ireland Limited, Fonticons, Inc. , Klaviyo Inc., Shopify Inc., Mailgun Technologies, Inc., PayPal Inc., Meta Platforms, Inc., Prospect One Sp. z o.o. sp. k., LinkedIn Corporation, HubSpot, Inc., Cloudflare, Inc., Hotjar Ltd.

Identifiers

Sold or Shared

Targeted Advertising

Personal Data processed: First name; Last name; Phone number; Email address + 48

Personal Information collected or disclosed:
  • first name
  • last name
  • phone number
  • email address
  • various types of Data as specified in the privacy policy of the service
  • Trackers
  • Usage Data
  • purchase history
  • billing address
  • shipping address
  • gender
  • date of birth
  • physical address
  • company name
  • profession
  • country
  • state
  • various types of Data
  • device information
  • city
  • ZIP/Postal code
  • province
  • county
  • latitude (of city)
  • longitude (of city)
  • metro area
  • geography/region
  • IP address
  • app information
  • device logs
  • operating systems
  • browser information
  • language
  • launches
  • number of sessions
  • session duration
  • scroll-to-page interactions
  • mouse movements
  • scroll position
  • keypress events
  • motion sensor events
  • touch events
  • video views
  • clicks
  • browsing history
  • search history
  • session statistics
  • page views
  • interaction events
  • page events
  • custom events
  • Application opens
Sensitive Personal Information collected or disclosed

payment info, username, password

Purposes:
  • Contacting the User
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
  • User database management
  • Traffic optimization and distribution
  • Spam and bots protection
  • Interaction with data collection platforms and other third parties
  • Interaction with online survey platforms
  • Heat mapping and session recording
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Google LLC, Klaviyo Inc., Shopify Inc., Mailgun Technologies, Inc., PayPal Inc., HubSpot, Inc., Cloudflare, Inc., Hotjar Ltd.

Service providers or contractors:

this Application

Commercial information

Sold or Shared

Targeted Advertising

Personal Data processed: Various types of data as specified in the privacy policy of the service; Trackers; Usage data; First name + 15

Personal Information collected or disclosed:
  • various types of Data as specified in the privacy policy of the service
  • Trackers
  • Usage Data
  • first name
  • last name
  • phone number
  • email address
  • purchase history
  • billing address
  • shipping address
  • gender
  • date of birth
  • physical address
  • company name
  • profession
  • country
  • state
  • various types of Data
  • device information
Sensitive Personal Information collected or disclosed

payment info, username, password

Purposes:
  • Handling payments
  • Managing contacts and sending messages
  • Platform services and hosting
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Google LLC, Klaviyo Inc., Shopify Inc., PayPal Inc.

Employment related information

Sold or Shared

Targeted Advertising

Personal Data processed: Trackers; Usage data; First name; Last name + 11

Personal Information collected or disclosed:
  • Trackers
  • Usage Data
  • first name
  • last name
  • gender
  • date of birth
  • phone number
  • physical address
  • email address
  • company name
  • profession
  • country
  • state
  • various types of Data
  • purchase history
Sensitive Personal Information collected or disclosed

username

Purposes:
  • Managing contacts and sending messages
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Klaviyo Inc., Mailgun Technologies, Inc.

Geolocation data

Sold or Shared

Targeted Advertising

Personal Data processed: City; Zip/postal code; State; Province + 34

Personal Information collected or disclosed:
  • city
  • ZIP/Postal code
  • state
  • province
  • country
  • county
  • latitude (of city)
  • longitude (of city)
  • metro area
  • geography/region
  • Usage Data
  • Trackers
  • IP address
  • device information
  • app information
  • device logs
  • operating systems
  • browser information
  • language
  • launches
  • number of sessions
  • session duration
  • scroll-to-page interactions
  • mouse movements
  • scroll position
  • keypress events
  • motion sensor events
  • touch events
  • video views
  • clicks
  • browsing history
  • search history
  • session statistics
  • page views
  • interaction events
  • page events
  • custom events
  • Application opens
Purposes:
  • Spam and bots protection
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Cloudflare, Inc.

Inferences drawn from other personal information

Sold or Shared

Targeted Advertising

Personal Data processed: City; Zip/postal code; State; Province + 34

Personal Information collected or disclosed:
  • city
  • ZIP/Postal code
  • state
  • province
  • country
  • county
  • latitude (of city)
  • longitude (of city)
  • metro area
  • geography/region
  • Usage Data
  • Trackers
  • IP address
  • device information
  • app information
  • device logs
  • operating systems
  • browser information
  • language
  • launches
  • number of sessions
  • session duration
  • scroll-to-page interactions
  • mouse movements
  • scroll position
  • keypress events
  • motion sensor events
  • touch events
  • video views
  • clicks
  • browsing history
  • search history
  • session statistics
  • page views
  • interaction events
  • page events
  • custom events
  • Application opens
Purposes:
  • Spam and bots protection
Retention period:

for the time necessary to fulfill the purpose

Sold or Shared:

Yes

Targeted Advertising:

Yes

Third-parties:

Cloudflare, Inc.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
  • the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
  • the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
  • the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
  • the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
  • the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have

  • The right to opt out of the processing of your Personal Information for Targeted Advertising;
  • The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Application, if not stated otherwise within this document.