Owner and Data Controller
BRAMS TECHNOLGIES LLC
AL SHAFAR TOWER
PO box 502765 Dubai UAE
DPO Europe :
BRAMS SA
Adrien Lachenal 26, 1201 Geneve, Switzerland
BRAMS sarl
210 Bd Abdelmoumen
20300 Casablanca, Morocco
Owner contact email: privacy@brams.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
first name; last name; phone number; company name; country; email address; city; number of employees; Usage Data; Cookies; address; password; VAT Number; profession; ZIP/Postal code; website; billing address; language; geographic position; various types of Data.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Backup saving and management, Contacting the User, User database management, SPAM protection, Hosting and backend infrastructure, Managing contacts and sending messages, Registration and authentication, Registration and authentication provided directly by this Website, Displaying content from external platforms, Location-based interactions, Social features, Analytics, Data transfer outside the EU, Advertising, Access to third-party accounts, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Platform services and hosting and Selling goods and services online.
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 Website
This Website 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 Website 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.
Contact email
Access the User's contact email address.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Access to third-party accounts
This type of service allows this Website 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.
Twitter account access (X Corp.)
This service allows this Website to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Facebook account access (Facebook, Inc.)
This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Contact email.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
-
Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google AdSense (Google Ireland Limited)
Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
X Ads conversion tracking (X Corp.)
X Ads conversion tracking is an analytics service provided by X Corp. that connects data from the X advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
7Pass (ProSiebenSat.1 Digital Data GmbH)
7Pass is an advertising service provided by ProSiebenSat.1 Digital Data GmbH.
Personal Data processed: Tracker; Usage Data.
Place of processing: Germany – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
-
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.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Google Analytics (Universal Analytics) with anonymized IP (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
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: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Backup saving and management
This type of service allows the Owner to save and manage backups of this Website 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 Website.
Backup on Google Drive (Google Inc.)
Google Drive is a service to save and manage backups 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: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website 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; email address; first name; last name; number of employees; phone number.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; inferences drawn from other personal information.
This processing constitutes:
Mailing list or newsletter (this Website)
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 Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: city; company name; country; email address; first name; last name; phone number.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
-
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Cloud Storage (Google Inc.)
Google Cloud Storage is a hosting 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: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google App Engine (Google Inc.)
Google App Engine is a hosting 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: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Microsoft Azure (Microsoft Corporation)
Microsoft Azure is a hosting service provided by Microsoft Corporation.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
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 Website.
The interaction and information obtained through this Website 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 Website isn’t being connected back to the User’s profile.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Location-based interactions
Geolocation (this Website)
This Website 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 Website.
Personal Data processed: geographic position.
Category of Personal Information collected according to the CCPA: geolocation data.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
- a Sharing in California
-
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
-
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
-
Platform services and hosting
These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Website.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Registration and authentication
By registering or authenticating, Users allow this Website 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 Website will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Google OAuth (Google Inc.)
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Linkedin OAuth (LinkedIn Corporation)
Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
OneDrive OAuth (Microsoft Corporation)
OneDrive OAuth is a registration and authentication service provided by Microsoft Corporation and is connected to the OneDrive network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube OAuth (Google Inc.)
YouTube OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the YouTube network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
-
Registration and authentication provided directly by this Website
By registering or authenticating, Users allow this Website 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 Website)
The User registers by filling out the registration form and providing the Personal Data directly to this Website.
Personal Data processed: address; billing address; city; company name; country; email address; first name; language; last name; password; phone number; profession; VAT Number; website; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information; inferences drawn from other personal information.
This processing constitutes:
-
Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
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.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Twitter Tailored Audiences (X Corp.)
Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of this Website with the Twitter advertising network.
Users can opt out from interest-based ads by going to: Personalization and Data.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
-
Selling goods and services online
Domaine .MA
This processing constitutes:
-
Social features
Inviting and suggesting friends (this Website)
This Website 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.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
SPAM protection
This type of service analyzes the traffic of this Website, 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 Inc.)
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: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
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 Website, 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 Website.
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 Website.
ZOHO CRM (Zoho Corporation Pvt. Ltd.)
ZOHO CRM is a User database management service provided by Zoho Corporation Pvt. Ltd., Zoho Corporation B.V., Zoho Corporation Pte. Ltd., Zoho (Beijing) Technology Co., Ltd., Zoho Japan Corporation or by Zoho Corporation GMBH, depending on how the Owner manages the Data processing.
Personal Data processed: email address; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
HubSpot Lead Management (HubSpot, Inc.)
HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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
-
CNDP
In accordance with the 09-08 law, you have the right to access, rectify, or oppose the processing of your personal data. This processing was authorized by the CNDP as per the authorization number D-M-156/2013 of April 23rd, 2013.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
-
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 Website depends on the payment system used.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer 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 Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
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, providing Users with the information required by law.
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 Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
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.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
various types of Data as specified in the privacy policy of the service, email address, Usage Data, Cookies, first name, last name, phone number, address, company name, profession, country, ZIP/Postal code, city, website, billing address, language, various types of Data, Trackers, Tracker
Sensitive Personal Information collected or disclosed ℹ️:
password, VAT Number
Purposes:
- Backup saving and management
- User database management
- SPAM protection
- Hosting and backend infrastructure
- Registration and authentication
- Registration and authentication provided directly by this Website
- Further information about Personal Data
- Displaying content from external platforms
- Social features
- Analytics
- Managing contacts and sending messages
- Data transfer outside the EU
- Advertising
- Access to third-party accounts
- Remarketing and behavioral targeting
- Interaction with external social networks and platforms
- Platform services and hosting
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google Inc., Zoho Corporation Pvt. Ltd., Microsoft Corporation, LinkedIn Corporation, HubSpot, Inc., Google Ireland Limited, X Corp., Facebook, Inc., Automattic Inc., ProSiebenSat.1 Digital Data GmbH
Service providers or contractors: this Website
-
Identifiers
Personal Information collected or disclosed:
first name, last name, phone number, company name, country, email address, city, number of employees, various types of Data as specified in the privacy policy of the service, address, profession, ZIP/Postal code, website, billing address, language, Usage Data, Cookies, About Me, Contact email
Sensitive Personal Information collected or disclosed ℹ️:
password, VAT Number
Purposes:
- Contacting the User
- User database management
- Managing contacts and sending messages
- Registration and authentication provided directly by this Website
- Remarketing and behavioral targeting
- Access to third-party accounts
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Zoho Corporation Pvt. Ltd., The Rocket Science Group, LLC., Sendgrid, HubSpot, Inc., X Corp., Facebook, Inc.
Service providers or contractors: this Website
-
Commercial information
Personal Information collected or disclosed:
first name, last name, phone number, company name, country, email address, city, number of employees, address, profession, ZIP/Postal code, website, billing address, language
Sensitive Personal Information collected or disclosed ℹ️:
password, VAT Number
Purposes:
- Contacting the User
- Registration and authentication provided directly by this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: this Website
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
first name, last name, phone number, company name, country, email address, city, number of employees, address, profession, ZIP/Postal code, website, billing address, language
Sensitive Personal Information collected or disclosed ℹ️:
password, VAT Number
Purposes:
- Contacting the User
- Registration and authentication provided directly by this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: this Website
-
Employment related information
Personal Information collected or disclosed:
first name, last name, phone number, address, email address, company name, profession, country, ZIP/Postal code, city, website, billing address, language
Sensitive Personal Information collected or disclosed ℹ️:
password, VAT Number
Purposes:
- Registration and authentication provided directly by this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: this Website
-
Geolocation data
Personal Information collected or disclosed:
geographic position
Purposes:
- Location-based interactions
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: this Website
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Website, if not stated otherwise within this document.