Owner and Data Controller
Kumele
Carl Spitzweg Straße 1
15831 Blankenfelde
Germany
Owner contact email: office@kumele.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
first name; last name; email address; username; device information; Tracker; Usage Data; geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geography/region; session duration; operating systems; Universally unique identifier (UUID); Data communicated while using the service; app information; country; date of birth; device logs; gender; company name; state; county; ZIP/Postal code; various types of Data; city; website; phone number; Calendar permission; Contacts permission; Camera permission; Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Social media accounts permission; Biometric Data access permission; Photo Library permission; Siri permission; Apple's speech recognition servers permission; Google Assistant permission; Data communicated in order to use the Service; payment data; password; picture; address; VAT Number; profile picture; User ID; billing address.
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:
Access to third-party accounts, Advertising, Analytics, Backup saving and management, Beta Testing, Commercial affiliation, Contacting the User, Content commenting, Content performance and features testing (A/B testing), Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Handling payments, Heat mapping and session recording, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with external social networks and platforms, Interaction with live chat platforms, Managing contacts and sending messages, Interaction with online survey platforms, Interaction with support and feedback platforms, Communication, Location-based interactions, Managing support and contact requests, Platform services and hosting, Registration and authentication, Registration and authentication provided directly by this Application, Remarketing and behavioral targeting, Social features, SPAM protection, Tag Management, Traffic optimization and distribution and User database management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Access Page CTA
Provides the access to manage call to actions on User-managed Pages.
Activities
Provides access to the User's list of activities.
Age range
Provides access to the User's age range.
Birthday
Provides access to the birthday.
Chat
Provides applications that integrate with Facebook Chat the ability to log in Users.
Contact email
Access the User's contact email address.
Create Events
Enables the application to create and modify events on the User's behalf.
Current City
Provides access to the User's current location.
Custom Friend Lists Access
Provides access to the names of custom lists the User has created to organize their friends.
Custom User Actions
Allows the app retrieve the actions published by another application as specified by the app namespace.
Deals
Read the deal activity.
device information
Email
Provides access to the User's primary email address.
Events
Provides access to the list of events the User is attending.
Friends' Activities
Provides access to the friends' list of activities.
Friends' birthdays
Provides access to the friends' birthdays.
Friends' Current Cities
Provides access to the friends' current locations.
Friends' Events
Provides access to the list of events the friends are attending.
Friends' Hometown
Provides access to the friends' hometown.
Friends' Photos
Provides access to the photos the friends have uploaded, and photos the friends have been tagged in.
Gender
Provides access to the User's gender.
Hometown
Provides access to the User's hometown.
Insights
Provides read access to the Insights data for pages, applications, and domains the user owns.
Instagram basic
Allows reading an Instagram account profile information and media.
Likes
Provides access to the list of all of the pages the User has liked.
List of Friends
Provides access to the User's list of friends that also use said app.
Pages User timezone
Grants access to a User’s time zone through the connected Page.
RSVP to Events
Enables the application to RSVP to events on the User's behalf.
Upload Photos
Add or modify user's photos.
User location
Allows reading the city name as listed in the location field of a User’s Facebook profile.
User subscriptions
Provides access to the User's subscriptions associated with the app.
Website
Provides access to the User's web site URL.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Apple's speech recognition servers permission
Used for sending the User's Data to Apple's speech recognition servers.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.
Biometric Data access permission
Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Contacts permission
Used for accessing contacts and profiles on the User's device, including the changing of entries.
Google Assistant permission
Used for sending the User's Data to Google Assistant (an artificial intelligence-powered virtual assistant).
Photo Library permission
Allows access to the User's Photo Library.
Precise location permission (non-continuous)
Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.
Siri permission
Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access Friend Lists; Access Page CTA; Activities; Age range; Birthday; Chat; Contact email; Create Events; Current City; Custom Friend Lists Access; Custom User Actions; Deals; device information; Email; Events; Friends' Activities; Friends' birthdays; Friends' Current Cities; Friends' Events; Friends' Hometown; Friends' Photos; Gender; Hometown; Insights; Instagram basic; Likes; List of Friends; Pages User timezone; RSVP to Events; Upload Photos; User location; User subscriptions; Website.
Place of processing: United States – Privacy Policy.
Stripe account access (Stripe Inc)
This service allows this Application to connect with the User's account on Stripe, provided by Stripe, Inc.
Personal Data processed: device information; email address; first name; last name; username.
Place of processing: United States – Privacy Policy.
Twitter account access (X Corp.)
This service allows this Application to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data processed: device information; first name; last name; username.
Place of processing: United States – Privacy Policy.
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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 Application.
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 cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Campaign Manager 360
Google Campaign Manager 360 is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
Google Campaign Manager 360 also allows the Owner to measure the campaign's performance, to set up placements, ads, and creatives, and to verify tag implementations (such as errors in the ad's formatting).
This Application is collecting and transmitting Data from the User through Google Campaign Manager 360 to media buyers bidding to purchase its inventory. These buyers may collect and store such Data and use such Data for retargeting or other advertising purposes.
Users may decide to disable all the ad personalization Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: geographic position; Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google AdSense
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
AdMob
AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy.
Facebook Audience Network
Facebook Audience Network is an advertising service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, In order to understand Facebook's use of Data, consult Facebook's data policy.
This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Lookalike Audience
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Application or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Shareaholic (Shareaholic, Inc.)
Shareaholic is an advertising and behavioral targeting service provided by Shareaholic, Inc. that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application. Users can opt out of Shareaholic's use of Trackers for ads personalization by visiting this opt-out page or following the instructions provided by AdChoices.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
ShareThis (Sharethis Inc.)
ShareThis is an advertising and behavioral targeting service provided by Sharethis Inc. that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application. Users can opt out of ShareThis's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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 Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Pinterest Conversion Tag (Pinterest, Inc.)
Pinterest Conversion Tag is an analytics service provided by Pinterest, Inc. that connects data from the Pinterest advertising network with actions performed on this Application.
Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Quora Conversion Pixel (Quora, Inc.)
Quora Conversion Pixel is an analytics service provided by Quora, Inc. that connects data from the Quora Platform with actions performed on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
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 Application.
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.
Yahoo Advertising conversion tracking (Yahoo! Inc.)
Yahoo Advertising conversion tracking is an analytics service provided by Yahoo! Inc. that connects data from the Yahoo advertising network with actions performed on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
viral loop
virality and leads generation
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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.
Facebook Analytics for Apps
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing,
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Flurry Analytics (Flurry, Inc.)
Flurry Analytics is an analytics service provided by Yahoo! Inc.
This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Flurry Analytics privacy policy.
If the User chooses to opt-out, Flurry will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward. The analytics service tracking will stop across all applications within the Flurry network.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of 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 order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features
Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: geography/region; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Analytics (Universal Analytics) with anonymized IP
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
User ID extension for Google Analytics
Google Analytics on this Application makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Application.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Wordpress Stats
Wordpress Stats is an analytics service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
YouTube Analytics and Reporting API
YouTube Analytics and Reporting API is a video content analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: device information; username.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
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Backup saving and management
This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
Amazon Glacier (Amazon)
Amazon Glacier is a service to save and manage backups provided by Amazon Web Services Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Beta Testing
This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.
App Center (Microsoft Corporation)
App Center is a beta testing service provided by Microsoft Corporation. This Application may also send push notifications to the User.
Personal Data processed: Data communicated while using the service; email address; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Beta by Crashlytics
Beta by Crashlytics is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Play Beta Testing
Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: country; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
HockeyApp (Microsoft Corporation)
HockeyApp is a beta testing service provided by Microsoft Corporation.
Personal Data processed: app information; Data communicated while using the service; date of birth; device information; device logs; email address; first name; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Commercial affiliation
This type of service allows this Application to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Application.
For details of which data are collected, please refer to the privacy policy of each service.
AliExpress Affiliate (Alibaba.com Singapore E-Commerce Private Limited)
AliExpress Affiliate is a commercial affiliation service provided by Alibaba.com Singapore E-Commerce Private Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Singapore – Privacy Policy.
Amazon Affiliation (Amazon)
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
ClickBank (Click Sales Inc.)
ClickBank is a banner commercial affiliation service provided by Click Sales Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Booking.com Affiliate Partner Programme (Booking.com B.V.)
Booking.com Affiliate Partner Programme is a commercial affiliation service provided by Booking.com B.V., part of the Priceline.com group.
Personal Data processed: Tracker; Usage Data.
Place of processing: Netherlands – Privacy Policy.
Rakuten Advertising Affiliate
Rakuten Advertising Affiliate is a banner commercial affiliation service provided by Rakuten Marketing LLC or by Rakuten Marketing LLC dba Rakuten Advertising, depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt out; European Union – Privacy Policy – Opt out.
LinkShare (Rakuten Marketing LLC)
LinkShare is a commercial affiliation service provided by Rakuten Marketing LLC.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Communication
warm welcome
Interaction with user on the web or par email.
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Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: city; company name; country; county; email address; first name; gender; last name; state; various types of Data; website; ZIP/Postal code.
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: city; company name; country; first name; last name.
Phone contact (this Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
mautic
Data collection and interaction through Email
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (this Application)
This Application has its own internal content comment system.
Personal Data processed: email address; first name; last name; Usage Data; username.
Facebook Comments
Facebook Comments is a content commenting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.
Firebase Remote Config
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Optimize
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Optimize 360
Google Optimize 360 is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").
This service allows the Owner to target groups of Users on the base of their past use of this Application. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Optimizely (Optimizely, Inc.)
Optimizely is an A/B testing service provided by Optimizely, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Visual Website Optimizer (Wingify)
Visual Website Optimizer is an A/B testing service provided by Wingify Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Apple's speech recognition servers permission; Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Calendar permission; Camera permission; Contacts permission; Google Assistant permission; Photo Library permission; Precise location permission (non-continuous); Siri permission; Social media accounts permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
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 Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Instagram widget
Instagram is an image visualization service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
YouTube video widget
YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
YouTube IFrame Player
YouTube IFrame Player is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; device information; Tracker.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
MyFonts (Monotype Imaging Inc.)
MyFonts is a typeface visualization service provided by Monotype Imaging Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
YouTube Data API
YouTube Data API is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate functions normally executed on YouTube so that Users can watch, find, and manage YouTube content directly on this Application.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of Trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Tracker.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
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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.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Bitpay (BitPay, Inc.)
Bitpay is a payment service provided by BitPay, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Coinbase (Coinbase Inc.)
Coinbase is a payment service provided by Coinbase, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Pay
Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Klarna (Klarna AB)
Klarna is a payment service provided by Klarna AB.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Sweden – Privacy Policy.
Payments processed via the Apple App Store (Apple Inc.)
This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.
Personal Data processed: payment data.
Place of processing: United States – Privacy Policy.
Payments processed via the Google Play Store
This Application uses a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
Personal Data processed: payment data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
PayPal Carrier Payments (PayPal Inc.)
PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile phone operator.
Personal Data processed: phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Paysafecard (Prepaid Services Company Limited)
Paysafecard is a payment service provided by Prepaid Services Company Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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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.
Crazy Egg (Crazyegg)
Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
SumoMe Heat Maps (Sumo Group Inc.)
SumoMe Heat Maps is a heat mapping service provided by Sumo Group Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
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: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
ClickTale (ClickTale Ltd.)
ClickTale is a heat mapping service provided by ClickTale Ltd.
Personal Data processed: Tracker; Usage Data.
Place of processing: Israel – Privacy Policy – Opt Out.
Decibel Insight (Decibel Insight Limited)
Decibel Insight is a heat mapping service provided by Decibel Insight Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some 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: United States – Privacy Policy; Canada – Privacy Policy; Brazil – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; India – Privacy Policy; Australia – Privacy Policy; China – Privacy Policy; Korea, Republic of – Privacy Policy; Japan – Privacy Policy; Singapore – Privacy Policy; Italy – Privacy Policy; Sweden – Privacy Policy; Bahrain – Privacy Policy; South Africa – Privacy Policy.
iubenda Consent Solution (iubenda srl)
iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.
Personal Data processed: Data communicated while using the service.
Place of processing: Italy – Privacy Policy.
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Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Airbrake (Airbrake Technologies, Inc.)
Airbrake is a monitoring service provided by Airbrake Technologies, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Web Performance (Web Performance, Inc.)
Web Performance is a monitoring service provided by Web Performance, Inc.Web Performance is a monitoring service provided by Web Performance, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)
Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Turkey – Privacy Policy.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.
Facebook Like button and social widgets
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing,
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Pinterest “Pin it” button and social widgets (Pinterest, Inc.)
The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube button and social widgets
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Mix button and social widgets (Mix Tech, Inc.)
The Mix button and social widgets are services allowing interaction with the Mix social network provided by Mix Tech, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Salesforce Live Agent (Salesforce.com, inc.)
Salesforce Live Agent is a service for interacting with the Salesforce live chat platform provided by Salesforce.com, inc.
Personal Data processed: company name; country; email address; first name; last name.
Place of processing: United States – Privacy Policy.
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Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
SurveyMonkey Widget
The SurveyMonkey Widget is a service for interacting with the SurveyMonkey online survey platform provided by SurveyMonkey Inc., SurveyMonkey Brasil Internet Ltda. or by SurveyMonkey Europe UC, depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; European Union – Privacy Policy.
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Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Application.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
GetSatisfaction Widget (Get Satisfaction)
The GetSatisfaction Widget is a service for interacting with the GetSatisfaction support and feedback platform provided by Get Satisfaction Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Geolocation (this Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Personal Data processed: geographic position.
Non-continuous geolocation (this Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed: geographic position.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
MailCow
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Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
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Cayzu
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Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Apple App Store (Apple Inc.)
This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
WordPress.com
WordPress.com is a platform provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows the Owner to build, run and host this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Play Store
This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; password; picture; Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; European Union – Privacy Policy.
Facebook Authentication
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Instagram Authentication
Instagram Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, and is connected to the Instagram social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Sign in with Apple (Apple Inc.)
Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
Twitter OAuth (X Corp.)
Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Pinterest OAuth (Pinterest, Inc.)
Pinterest OAuth is a registration and authentication service provided by Pinterest, Inc. and is connected to the Pinterest social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Registration and authentication provided directly by this Application
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed: address; billing address; city; company name; country; county; date of birth; email address; first name; gender; last name; password; profile picture; state; Tracker; Usage Data; User ID; username; various types of Data; VAT Number.
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension
Google Ad Manager Audience Extension 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 tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Signals
This Application uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Application with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Social features
Inviting and suggesting friends (this Application)
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
Public profile (this Application)
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.
Personal Data processed: first name; geographic position; picture; username.
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SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google 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: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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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.
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 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: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
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Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Access the address book
This Application may request access to your address book.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
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Browser Fingerprinting
Browser Fingerprinting creates an identifier based on a device's unique combination of characteristics (e.g. IP address, HTTP header, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User's browsing behavior across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.
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Global TCF v1 Cookie (euconsent)
Global TCF v1 Cookie (euconsent) stores User advertising tracking preferences under the .consensu.org domain. When a Global TCF v1 Cookie (euconsent) is set by the iubenda Cookie Solution, also a local 'cache' Cookie is stored in the local domain.
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Global TCF v2 Cookie (euconsent-v2)
Global TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences under the .consensu.org domain. When a Global TCF v2 Cookie (euconsent-v2) is set by the iubenda Cookie Solution, also a local 'cache' Cookie is stored in the local domain.
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iubenda CCPA Cookie (usprivacy)
iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain.
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iubenda Consent Solution localStorage
iubenda ConS JS library localStorage (IUB_DATA) temporarily stores pending data in a storage space internal to the User's browser (localStorage) until it's received by the API, then it is deleted.
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iubenda Cookie Solution (consent Cookie)
iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers in the local domain.
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iubenda Cookie Solution (remote consent Cookie)
Remote iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers under the .iubenda.com domain.
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Preference Cookies
Preference Cookies store the User preferences detected on this Application in the local domain such as, for example, their timezone and region.
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Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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Push notifications for direct marketing
This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.
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Site specific TCF v1 Cookie (euconsent)
Site specific TCF v1 Cookie (euconsent) stores User advertising tracking preferences in the local domain.
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Site specific TCF v2 Cookie (euconsent-v2)
Site specific TCF v2 Cookie (euconsent-v2) stores User advertising tracking preferences in the local domain.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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User identification via a universally unique identifier (UUID)
This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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The Service is intended for adults
Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.
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Pseudonymous use
When registering for this Application, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on this Application shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on this Application, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Additional information for Users in Brazil
Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.
To do so, we may use one of the following legal means:
- specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
- standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
- global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
- seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD
We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:
- the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
- the nature of the personal information subject to the transfer;
- the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
- the adoption of suitable security measures;
- the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
- any other pertinent circumstance related to the relevant transfer.
Transfer of personal information outside of Brazil based on your consent
We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
You may withdraw your consent at any time.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.