Owner and Data Controller
Dig Media Inc. dba Investing News Network
1200 - 736 Granville Street,
Vancouver, BC V6Z 1G3 Canada
Owner contact email: info@investingnews.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; geographic position; language; first name; last name; phone number; province; state; country; ZIP/Postal code; city; address; scroll-to-page interactions; metro area; income information; device information; session duration; purchase history; Age range; profession; Education History; browser information.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Interaction with external social networks and platforms, Advertising, Displaying content from external platforms, Remarketing and behavioral targeting, Managing contacts and sending messages, Hosting and backend infrastructure, Contacting the User, User database management, Traffic optimization and distribution, Tag Management and Registration and authentication provided directly by this Website.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google AdSense (Google Inc.)
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 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: US – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Google Ad Manager (Google Inc.)
Google Ad Manager is an advertising service provided by Google LLC 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 Website and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.
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:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Direct Email Marketing (DEM) (this Website)
This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.
Personal Data processed: email address.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA
Bombora (Bombora Inc.)
Bombora is an advertising service provided by Bombora Inc.
Personal Data processed: Age range; city; country; device information; Education History; geographic position; income information; language; metro area; profession; purchase history; scroll-to-page interactions; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; ZIP/Postal code.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; personal information; commercial information; internet or other electronic network activity information; geolocation data; employment related information; education information; inferences drawn from other personal information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
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targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Taboola (Taboola Inc.)
Taboola is an advertising service provided by Taboola Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Website. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) (Google Inc.)
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 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: US – Privacy Policy – Opt Out.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Quantcast Measure (Quantcast Corporation)
Quantcast Measure is an analytics service provided by Quantcast Corporation.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: browser information.
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:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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Contacting the User
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: address; city; country; email address; first name; last name; phone number; province; state; ZIP/Postal code.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the VCDPA, CPA, CTDPA and UCPA
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: email address.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
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a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this 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.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. 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:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this 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.
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.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this 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.
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: US – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
targeted advertising according to the CPA, CTDPA and UCPA
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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a sale according to the CCPA and VCDPA
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
OneSignal (Lilomi, Inc.)
OneSignal is a message sending service provided by Lilomi, Inc.
OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Depending on the permissions granted to this Website, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User's device. This Website uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.
The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal's use of Data, consult OneSignal's privacy policy.
Push notifications opt-out
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 some or all of the apps on the particular device.
Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones.
Different device configurations, or updates to devices, may affect or change how these indicated settings work.
Personal Data processed: Cookies; email address; geographic position; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: identifiers.
This processing constitutes:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA
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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: email address.
Category of personal information collected according to the CCPA: identifiers.
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
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.
Google Ads Remarketing (Google Inc.)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Remarketing with Google Analytics (Google Inc.)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – 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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Google Ad Manager Audience Extension (Google LLC)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them.
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:
-
a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to the CCPA: internet or other electronic network activity information.
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Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Trackers.
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 according to the CCPA, VCDPA, CPA, CTDPA and UCPA
-
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.
MoEngage
MoEngage, Inc. (“MoEngage,” “us” or “we”) provides SaaS (software as a service) (the “Service”) that enables the providers of mobile applications and websites (the “App Providers”) to understand how end users who download, access and/or interact with App Providers’ services (the “End Users”) interact with their services. This privacy policy (the “Privacy Policy”) describes how we collect, use, and disclose data collected through the MoEngage Platform (the “Platform”), as a part of our Service. European Union should be sure to read the important information provided under the section - “Additional Information for European Union Users” in this Privacy Policy. We might update our Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Platform or by sending you an email or other notification prior to the changes becoming effective. We will also indicate when the changes will become effective. Please review our Privacy Policy on a regular basis. Any information that we collect is subject to the privacy policy in effect at the time such information is collected. This Privacy Policy only applies to MoEngage and does not apply to the practices of companies that MoEngage does not own or control, or to people that MoEngage does not employ or manage. This Privacy Policy has some provisions that only apply to App Providers and End Users, respectively, and it also has provisions that apply to both App Providers and End Users. Please read the applicable Privacy Policy provisions carefully before proceeding.
FOR END USERS
How we collect and use information from the End Users
We obtain information about End Users to provide App Providers with behavioral and analytics data related to how End Users interact with their products and services (the “Applications”). We do not directly get personal information from End Users; we collect information using tracking code technology that App Providers install in their Applications and share with us pursuant to their information collection practices, which are typically outlined in a privacy policy like this one and made available on the App Provider’s website. We encourage all End Users to read the privacy policies of the Applications they access or use. The App Providers provide us with the following types of information about End Users: When an App Provider embeds our tracking code into its Applications, we access or obtain Personally Identifiable Information (“PII”) such as an End User’s email address, name, and phone number, depending on the selections the applicable App Provider makes via the MoEngage Software Development Kits (the “SDKs”). We also access or obtain additional information about End Users’ use of App Providers’ Applications and End Users’ devices, such as the actions taken, content viewed, messages viewed, messages clicked, offers accepted, search terms entered, advertisements clicked, applications opened, applications sent to the background, transactions in which an End User engaged, application name, application version, application bundle identifier, operating system name, operating system version, unique device identifiers, IP addresses, and access date, time, and location information. Please ensure you read, understand, and accept the privacy policies, and any terms of use of the App Provider that uses the MoEngage Service. By using our Service, you expressly relieve MoEngage from any and all liability arising from your use of the App Providers service. We analyze and use this information to provide and improve the MoEngage Service. MoEngage collects information under the direction of our App Providers and has no direct relationship with the End Users whose personal data it processes. If you are a customer of one of our App Providers and would no longer like to be contacted by one of our App Providers that use the MoEngage Service, please contact the App Provider directly. If the App Provider fails to respond to your request within 30 days, you may contact us with your request at privacy@moengage.com.
How long do we retain information collected from End Users?
We will retain personal data we process on behalf of our App Providers for as long as needed to provide services to our App Providers. We will also retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. An End User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to our App Providers. If requested by App Providers to remove or access data, we will respond within 30 days.
Communications
App Providers are able to send you, the End Users, push notifications, thought In-apps or email communications through the MoEngage Service.
Opt-Out
An End User who seeks to opt-out must direct their query to their App Providers. The App Providers may then request us to opt-out the said End User, which we shall do so within 30 days. Alternatively, the End User may contact us directly, by sending opt-out requests to privacy@moengage.com.
FOR APP PROVIDERS
Why do we collect information from App Providers?
We collect and use information from App Providers to provide our Service, to improve our Service, and to administer your Account, and to personalize End User experience.
Personal Information
When you, as an App Provider, create an Account or when you request information about the MoEngage Service, we’ll collect certain information that can be used to identify you, such as your name and email address (“PII”). We may also collect information that cannot be used to identify you, such as Account preferences.
Modifying and Deleting Your Information
You can access and modify the PII associated with your Account by accessing the user settings in the MoEngage Service. MoEngage acknowledges that EU individuals have the right to access and delete the personal information that we maintain about them. If you want us to delete your PII and your Account, please contact us at privacy@moengage.com with your request. We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
FOR END USERS AND APP PROVIDERS
Our Cookie Policy
MoEngage uses “cookies,” which are small text files that are placed by web servers and used to remember your preferences and settings. We use cookies to:
- analyzing trends
- administering the site
- tracking users’ movements on the website
- gather demographic information about our user base as a whole
- tracking your login and interaction with our website
We may receive reports based on the use of these technologies on an individual as well as aggregated basis. You can change your browser settings to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser does not accept cookies, however, you may not be able to easily access all aspects of our Service. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use locally stored objects (LSOs) such as HTML5 to collect and store information.
Opting-Out
Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising:
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform: http://www.youronlinechoices.com/
- The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
Information Related to Use of The Platform
We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
Information Shared with our Subsidiaries
Sometimes we may transfer your PII to our Indian subsidiary to provide you with better service or for troubleshooting purposes. Our Indian subsidiary is bound by the principles of Standard Contractual Clauses and the obligations under this Privacy Policy. If you have any questions or concerns related to the transfer of PII to our Indian subsidiary, you contact us at privacy@moengage.com.
Information Shared with our Service Providers
We may engage third-party Service Providers to work with us to administer and provide the MoEngage Service such as sending you emails, storing data, etc. These third-party Service Providers have access to PII only for the purpose of performing the MoEngage Service on our behalf and are expressly obligated not to disclose or use your PII for any other purpose. The End Users may reach us at privacy@moengage.com if they require further information about the third -party Service Provider, the services that they are providing, or their privacy policy.
Information Shared with Third Parties
We may share aggregated information and non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes. We will not share the End User PII collected for one App Provider with third parties.
Information Disclosed for our Protection and the Protection of Others
It is our policy to protect App Providers and End Users from having their privacy violated through abuse of the legal systems, whether by individuals, entities or government and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about App Providers or End Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary:
(i) to satisfy or comply with any law, regulation or legal process or to respond to lawful requests, including subpoenas, warrants or court orders;
(ii) to protect our property, rights and safety and the rights, property and safety of third parties or the public in general; and
(iii) to prevent or stop activity we consider to be illegal or unethical. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Data Security
We take reasonable measures to protect the information that we collect from or receive from App Providers or End Users (including PII) from unauthorized access, use or disclosure. When you enter sensitive information (such as login credentials) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting on our Platform in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Sites
Our Service may contain links to other websites and services. Any information that an App Provider or End User provides on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services, and we are not responsible for the content, privacy or security practices and policies of those websites or services. We recommend that App Providers and End Users carefully review the privacy policies of other websites and services that they access.
Social Media Features
Our Platform includes Social Media Features, such as the Facebook button and widgets, such as the “Share” button, or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Platform. Your interactions with these Features are governed by the privacy policy of the company providing it.
Our Policy Toward Children
Our Service is not directed to children under the age of 13. MoEngage users must not be under the age of 13. We do not target any portion of our service to children under the age of 13, and we will delete any accounts or data of users that we believe to be under the age of 13 to be in compliance with the Children’s Online Privacy Protection Act. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at privacy@moengage.com.
California Privacy Rights.
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact MoEngage via email at privacy@moengage.com.
Additional Information for European Union Users
Personal Information
All references to “Personal Information”, “Personally Identifiable Information” or “Personal data” are equivalent to the definition of “personal data” under GDPR.
MoEngage as a Data Controller
For App Providers and visitors of the MoEngage website, MoEngage Inc. is the controller of your personal information for purposes of European data protection legislation.
MoEngage as a Data Processor
MoEngage processes the personal data of end users on behalf of the App Providers and acts as a Data Processor on behalf of App Providers, who act as Data Controller
Data Protection Officer
Our Data Protection Officer can be reached at privacy@moengage.com.
Your Rights
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold -
Access: To provide the personal information we hold for you
Rectify: To rectify the incorrect personal information we are holding for you
Delete: To erase the personal information. Transfer: Send a machine readable copy of your personal information to you or a third party of your choice.
Restrict: To restrict the processing of your personal information.
Opt-out: Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails. You can submit these requests by email to privacy@moengage.com. We may require some information to authenticate your request. We may reject your request as applicable under law in which case we will inform you of the legal basis for rejecting your request. . If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at privacy@moengage.comFor End Users: MoEngage is a service provider that processes data on behalf of App Providers, any requests relating to European Users’ exercise of their rights of access, rectification, erasure, or restriction under the European General Data Protection Regulation (“GDPR”) must be provided to MoEngage by an App Provider. App Providers can notify MoEngage of these requests directly. You can refer this article for more information. Moreover, MoEngage supports functionality to allow App Providers to respect granular controls regarding User data privacy rights. App Providers can flag in the MoEngage SDK that a particular User has requested that their data not be processed by MoEngage, in which case MoEngage will no longer process engagement data on behalf of the App Provider for that User. For App Providers: App Providers who are users of MoEngage Service and who are residents of the European Union may request to get a confirmation in MoEngage is processing your data, access this or request to rectify, delete or restrict processing of this information. For any such request, you may send an email to us at privacy@moengage.com after 25th May 2018. Use for new purpose: We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Additional Information for California Users
“Personal Information” for the purpose of this section has the meaning given to this term in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information specifically excluded from within the scope of the CCPA.
Collection of Personal Information: Depending on your use / interaction with us, we may collect the following categories of Personal Information from you:
Statutory Category of Personal Information Collected Nature of the Personal Information Collected Purpose for Collection Source
Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Data about what an individual has purchased from MoEngage (including tickets to MoEngage-sponsored events)
· Data about what an individual has downloaded from the MoEngage Website Register for, attend and/or otherwise take part in our events webinars or contests
You
MoEngage
Affiliates
Partners
Data providers
Identifiers. Real name, alias, postal address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.
First Name
Last Name
Phone Number
Email address
Company name
Use our Services as an authorized user
Receive communications from us
Responding to your requests for support or information;
You
MoEngage
Inferences. The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
May be derived from your:
Device Data (as described in Section 1.2)
Usage Data (as described in Section 1.2)
Job title
Company size
Enabling us to understand who is interested in learning about our products, services, content, and company-related initiatives;
MoEngage
Data providers
Online Identifiers. An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol (IP) address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology
Device data (as described in Section 1.2)
Unique customer number (assigned randomly by MoEngage)
Analyzing overall trends on our Website to help us to provide and improve our Website and to ensure its security and continued proper functioning;
MoEngage
Data providers
Professional or Employment Information. information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations)
Current company
Current job title
Industry
Sending messages to the users of our Services with respect to technical alerts, updates, security notifications, and educational and administrative communications
You
Data Providers
Audio, electronic, visual, thermal, olfactory, or similar information. Audio and video recordings.
You
MoEngage
Protected Classification Characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). We do not intentionally collect this data, but certain characteristics may be revealed in identity data or other information we collect.
We do not sell your Personal Information in any form. We do, however, use the Personal Information shared by you for the purpose of internet based targeted advertising of our own services. We do not offer any financial incentive programs to our users.
SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES
We may share and disclose Personal Data to the following types of third parties and for the following purposes:
To customers – We may disclose information to our customers in the form of aggregated, anonymous data about the way the Services have been used to enable us to provide and improve our Services, to provide strategic advice to our customers, and to further and enhance our role as a thought leader in the industry;
To vendors, consultants and other service providers - We may disclose information to third-party vendors, consultants and other service providers in connection with our marketing efforts, or in connection with our general business purposes;
To comply with laws - We may disclose information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or governmental request;
To protect our legal rights - We may also disclose information where we believe it necessary in order to protect or exercise, establish or defend our legal rights;
Business transfers - We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
To provide our Services - We use sub-processors in our provision of the MoEngage Services to our customers, such as third-party hosting providers and third-party database support services. Some of these third-party sub-processors may have logical access to data about you, but in all cases, any subprocessor to whom we disclose any information will be subject to a written agreement containing confidentiality protections designed to protect any Personal Data that is shared with them;
To manage events - If you use our Website to register for an event or webinar organized by one of our partners who may be a co-sponsor of the event, we may share your Personal Data with the co-sponsor to the extent this is required to process your registration and ensure your participation in the event; in such instances, our co-sponsor will process the relevant Personal Data as a separate controller and the sponsor’s use and control over your Personal Data will be governed by the sponsor’s privacy policy;
To advisors - In individual instances, we may share Personal Data with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance and accounting services, but only to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
To affiliates - We may share Personal Data with affiliates within the MoEngage group and companies that we may acquire in the future when they are made part of the MoEngage group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our Website or for customer support, marketing, technical operations or account management purposes; and
Publicly shared data - Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our Website may be read, collected and used by others who visit these forums, depending on your account settings.
Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third-parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Non-discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights.
Exercising your Rights: You can request to exercise your information, access and deletion rights by writing to privacy@moengage.com. We will need to confirm your identity and California residency to process your information, access or deletion requests, and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Response Timing: We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
International Data Transfers:
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
- Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
- For transfers to third parties in the United States, ensuring they participate in the E.U.-U.S. Privacy Shield Framework, or Standard Contractual Clauses, as applicable.
Contact Us
Please contact us at privacy@moengage.com if you have any questions about our Privacy Policy. Or you may mail us your questions or concerns at: Attn: Privacy and Security Office
MoEngage, Inc.
3575 Bankhead Road.
Loomis, CA 95650
This processing constitutes:
-
a sale according to the VCDPA, CPA, CTDPA and UCPA
- a sharing according to the CCPA
-
targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
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.
Further information for California consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, personal information, commercial information, internet or other electronic network activity information, geolocation data, employment related information, education information and inferences drawn from other personal information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this 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 Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, employment related information and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, employment related information and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this 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 o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CTDPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, employment related information and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the UCPA.
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, employment related information and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this 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)
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 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.
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.
Age range
Provides access to the User's age range.
Education History
Provides access to education history.
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.