Owner and Data Controller
Company Name: Leadplay OÜ
Address: Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111
Country: Estonia
VAT number: EE102382529
Owner contact email: contact@couponert.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Trackers; Usage Data; Universally unique identifier (UUID); unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); city; ZIP/Postal code; state; province; country; county; latitude (of city); longitude (of city); metro area; geography/region; 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; number of Users; various types of Data; time zone; diagnostic events; layout details; positional information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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 Website.
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 Website (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, Traffic optimization and distribution, Spam and bots protection, Analytics, Remarketing and behavioral targeting, Displaying content from external platforms, Collection of privacy-related preferences, Hosting and backend infrastructure, Data transfer outside the EU, Commercial affiliation and Heat mapping and session recording.
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 Website, 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 Website. 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.
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Microsoft Advertising Universal Event Tracking (Microsoft Corporation)
Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on this Website.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
Google Ads conversion tracking
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Direct Advertising (this Website)
This Website uses User Data to propose services or products provided by third parties, related or unrelated to the product or service provided by this Website.
Direct Advertising may involve the use of Trackers to monitor Users’ behavior and serve personalized ads. Users may opt-out of ad personalization by visiting their device settings or following the instructions provided by YourOnlineChoices and AdChoices.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
Google Ads Similar audiences
Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Website.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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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 4
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Google Analytics Advertising Reporting Features
Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
Wecantrack (We Can Track B.V.)
Wecantrack is affiliate conversion tracking software. Wecantrack provides an analytical data tracking, processing, attribution and integration tool that helps the Owner leverage traffic, campaign and conversion data.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Netherlands – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
Everflow (Everflow Technologies Inc.)
Everflow is a cloud-based performance marketing platform that allows the owner to manage the affiliation and monitor marketing initiatives.
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 or other electronic network activity information.
Browser Compatibility Data Collection
This service collects and processes browser-related data (e.g., browser type, version, and compatibility) to optimize the user experience and ensure compatibility with various browsers. The collected data may include the user agent string, browser version, and other relevant browser details.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
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Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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Collection of privacy-related preferences
This type of service allows this Website to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on this Website.
Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Commercial affiliation
This type of service allows this Website 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 Website.
For details of which data are collected, please refer to the privacy policy of each service.
Capital One Shopping (Capital One Services, LLC)
Capital One Shopping is a free browser tool that automatically searches for online coupons, better prices and rewards at over 30,000 online retailers. The Owner advertises the Capital One shopping extension as an affiliate.
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 or other electronic network activity information.
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer abroad based on standard contractual clauses (this Website)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
Category of Personal Information collected according to the CCPA: identifiers.
Data transfer abroad based on Data Privacy Framework UE - USA
The transfer of Personal Data from the EU to the United States occurs on the basis of the Data Privacy Framework. The Data Privacy Framework List lists the services covered by the agreement.
Data Privacy Framework List
For all other services, the transfer of Personal Data is based on standard Personal Data protection clauses adopted by the European Commission.
Users may request further information by contacting the Data Controller at the contact details indicated in this document.
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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 Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Heat mapping and session recording
Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: clicks; country; custom events; device information; diagnostic events; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions; session duration; time zone; Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
Hetzner Online GmbH
Hetzner is a hosting and backend service provided by Hetzner Online GmbH.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Spam and bots protection
This type of service analyzes the traffic of this Website, 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 Bot Management (Cloudflare, Inc.)
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.
Place of processing: United States – Privacy Policy.
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.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
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Traffic optimization and distribution
This type of service allows this Website 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 Website 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.
Cloudflare (Cloudflare, Inc.)
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 Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Trackers; 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: identifiers; internet or other electronic network activity information.
jsDelivr CDN (Prospect One Sp. z o.o. sp. k.)
jsDelivr CDN is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.
Personal Data processed: Usage Data.
Place of processing: Poland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Google Hosted Libraries (Google LLC)
Google Hosted Libraries is a traffic optimization and distribution service provided by Google LLC.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
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.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
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 Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Trackers, Usage Data, Universally unique identifier (UUID), unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, 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, number of Users, time zone, diagnostic events, layout details, positional information
Purposes:
- Advertising
- Tag Management
- Traffic optimization and distribution
- Spam and bots protection
- Analytics
- Remarketing and behavioral targeting
- Displaying content from external platforms
- Collection of privacy-related preferences
- Heat mapping and session recording
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Microsoft Corporation, Google LLC, Cloudflare, Inc., iubenda srl, this Website, Prospect One Sp. z o.o. sp. k.
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Identifiers
Personal Information collected or disclosed:
Trackers, Universally unique identifier (UUID), Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, city, ZIP/Postal code, state, province, country, county, latitude (of city), longitude (of city), metro area, geography/region, 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, various types of Data, time zone, diagnostic events, layout details, positional information
Purposes:
- Advertising
- Traffic optimization and distribution
- Spam and bots protection
- Hosting and backend infrastructure
- Data transfer outside the EU
- Analytics
- Heat mapping and session recording
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Microsoft Corporation, Cloudflare, Inc., Amazon Web Services, Inc., this Website, Google LLC
Service providers or contractors: this Website
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Geolocation data
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, time zone, diagnostic events, layout details, positional information
Purposes:
- Spam and bots protection
- Heat mapping and session recording
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare, Inc., Microsoft Corporation
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Inferences drawn from other personal information
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
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
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 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 Website.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, 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 Website and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.
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 Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (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 Website 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 Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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 Website 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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website 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 Website, if not stated otherwise within this document.