Owner and Data Controller
Michael Erath
1048 N 44th St.
Suite 100
Phoenix, AZ 85008
Owner contact email: startclimbing@nextlevelgrowth.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Trackers; Usage Data; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; email address; first name; last name; phone number; company name; various types of Data; number of Users; session statistics; city; ZIP/Postal code; state; province; country; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; device information; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; video views; browsing history; search history; page views; interaction events; page events; custom events; Application opens; order ID; data relating to the point of sale; Data communicated while using the service; user subscriptions; shipping address; User ID; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); profession; gender; date of birth; physical address; website; user content; profile picture; social media accounts; last date an email was sent; date of the message; time the message was sent; time the message was received; sender of the message; message importance; email opens; contact info; billing address; purchase history; geographic position; screenshots; workplace.
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:
Displaying content from external platforms, Advertising, Tag Management, Spam and bots protection, Managing contacts and sending messages, Contacting the User, Traffic optimization and distribution, Registration and authentication provided directly by this Website, Analytics, Interaction with data collection platforms and other third parties, Managing support and contact requests and Building and running 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 for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
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:
GoDaddy Digital Marketing Suite (GoDaddy.com, LLC)
GoDaddy Digital Marketing Suite is a digital marketing service provided by GoDaddy.com, LLC.
Personal Data processed: clicks; Data communicated while using the service; email address; first name; interaction events; last name; page views; profile picture; social media accounts; user content.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; audio, electronic, visual, thermal, olfactory, or similar information.
This processing constitutes:
- a sale in California
- a Sharing in California
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics 4 (Google 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: number of Users; session statistics; 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:
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Website.
Personal Data processed: browser information; browsing history; city; clicks; country; Data communicated while using the service; data relating to the point of sale; email address; first name; IP address; last name; order ID; page views; phone number; search history; shipping address; state; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID; user subscriptions; ZIP/Postal code.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
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Building and running this Website
Key components of this Website are built and run directly by the Owner by making use of the software listed below.
WordPress (self-hosted) (this Website)
This Website is built and run by the Owner via a CMS software (Content Management System) called WordPress.
Personal Data processed: billing address; city; company name; contact info; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; phone number; physical address; profession; purchase history; screenshots; shipping address; Usage Data; workplace.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, thermal, olfactory, or similar information; employment related information; inferences drawn from other personal information.
This processing constitutes:
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Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: company name; email address; first name; last name; phone number.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; state; Trackers; Usage Data; website; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; employment related information.
This processing constitutes:
- a Sale in the United States
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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.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, 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:
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:
-
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Mailchimp widget (Intuit Inc.)
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address; first name; last name; phone number; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a sale in California
- a Sharing in California
MailerLite widget (UAB "Mailerlite")
The MailerLite widget is a service for interacting with the MailerLite email address management and message sending service provided by UAB "Mailerlite".
Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; Trackers; Usage Data; various types of Data.
Place of processing: Lithuania – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
- a sale in California
- a Sharing in California
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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.
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: company name; email address; first name; last name; phone number.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data processed: various types of Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a sale in California
- a Sharing in California
GoDaddy Professional Email (GoDaddy.com, LLC)
GoDaddy Professional Email is an email address management and message-sending service provided by GoDaddy.com, LLC.
Personal Data processed: date of the message; email address; email opens; first name; last date an email was sent; last name; message importance; sender of the message; time the message was received; time the message was sent; Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a sale in California
- a Sharing in California
-
Managing support and contact requests
This type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Mailchimp Inbox (Intuit Inc.)
Mailchimp Inbox is a support and feedback management service provided by Intuit Inc.
Personal Data processed: email address; Usage Data; user content.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a sale in California
- a Sharing in California
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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: various types of Data.
Category of Personal Information collected according to the CCPA: identifiers.
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Spam and bots protection
This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Google reCAPTCHA (Google LLC)
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; 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; inferences drawn from other personal information.
Cloudflare Bot Management (Cloudflare, Inc.)
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data; inferences drawn from other personal information.
This processing constitutes:
-
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: 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.
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Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare, Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
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.
Further information for Users
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Trackers, Usage data, Answers to questions, Clicks, Keypress events, Motion sensor events, Mouse movements, Scroll position, Touch events, Various types of data as specified in the privacy policy of the service, Number of users, Session statistics, City, Zip/postal code, State, Province, Country, County, Latitude (of city), Longitude (of city), Metro area, Geography/region, Ip address, Device information, App information, Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-to-page interactions, Video views, Browsing history, Search history, Page views, Interaction events, Page events, Custom events, Application opens, Email address, First name, Last name, Phone number, Order id, Data relating to the point of sale, Data communicated while using the service, User subscriptions, Shipping address, User id, Unique device identifiers for advertising (google advertiser id or idfa, for example), Profession, Gender, Date of birth, Physical address, Company name, Website, User content, Profile picture, Social media accounts, Last date an email was sent, Date of the message, Time the message was sent, Time the message was received, Sender of the message, Message importance, Email opens, Various types of data, Contact info, Billing address, Purchase history, Geographic position, Screenshots, Workplace
Purposes:
- Displaying content from external platforms
- Advertising
- Tag Management
- Spam and bots protection
- Traffic optimization and distribution
- Analytics
- Interaction with data collection platforms and other third parties
- Contacting the User
- Managing contacts and sending messages
- Managing support and contact requests
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Vimeo, LLC, Google LLC, Meta Platforms, Inc., Cloudflare, Inc., Intuit Inc., GoDaddy.com, LLC, UAB "Mailerlite", this Website
Service providers or contractors: this Website
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Inferences drawn from other personal information
Personal Information collected or disclosed:
Usage data, Trackers, Answers to questions, Clicks, Keypress events, Motion sensor events, Mouse movements, Scroll position, Touch events, City, Zip/postal code, State, Province, Country, County, Latitude (of city), Longitude (of city), Metro area, Geography/region, Ip address, Device information, App information, Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-to-page interactions, Video views, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom events, Application opens, First name, Last name, Contact info, Shipping address, Billing address, Physical address, Purchase history, Email address, Phone number, Data communicated while using the service, Company name, Date of birth, Gender, Geographic position, Profession, Screenshots, Workplace
Purposes:
- Spam and bots protection
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC, Cloudflare, Inc., this Website
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Identifiers
Personal Information collected or disclosed:
Email address, First name, Last name, Phone number, Company name, Various types of data as specified in the privacy policy of the service, Trackers, Various types of data, City, Zip/postal code, State, Province, Country, County, Latitude (of city), Longitude (of city), Metro area, Geography/region, Usage data, Ip address, Device information, App information, Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch events, Video views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom events, Application opens, Order id, Data relating to the point of sale, Data communicated while using the service, User subscriptions, Shipping address, User id, Unique device identifiers for advertising (google advertiser id or idfa, for example), Profession, Gender, Date of birth, Physical address, Website, User content, Profile picture, Social media accounts, Last date an email was sent, Date of the message, Time the message was sent, Time the message was received, Sender of the message, Message importance, Email opens, Contact info, Billing address, Purchase history, Geographic position, Screenshots, Workplace
Purposes:
- Managing contacts and sending messages
- Contacting the User
- Traffic optimization and distribution
- Registration and authentication provided directly by this Website
- Spam and bots protection
- Interaction with data collection platforms and other third parties
- Analytics
- Advertising
- Managing support and contact requests
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Intuit Inc., Cloudflare, Inc., Mailgun Technologies, Inc., Meta Platforms, Inc., GoDaddy.com, LLC, UAB "Mailerlite", this Website
Service providers or contractors: this Website
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Commercial information
Personal Information collected or disclosed:
Email address, First name, Last name, Phone number, Company name, Trackers, Usage data, Order id, Data relating to the point of sale, Data communicated while using the service, User subscriptions, Shipping address, Browsing history, Clicks, Search history, Page views, City, Zip/postal code, State, Country, User id, Ip address, Browser information, Unique device identifiers for advertising (google advertiser id or idfa, for example), Profession, County, Gender, Date of birth, Physical address, Website, Various types of data, Contact info, Billing address, Purchase history, Device information, Geographic position, Language, Screenshots, Workplace
Purposes:
- Managing contacts and sending messages
- Contacting the User
- Analytics
- Interaction with data collection platforms and other third parties
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Intuit Inc., Meta Platforms, Inc., UAB "Mailerlite", this Website
Service providers or contractors: this Website
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Geolocation data
Personal Information collected or disclosed:
City, Zip/postal code, State, Province, Country, County, Latitude (of city), Longitude (of city), Metro area, Geography/region, Usage data, Trackers, Ip address, Device information, App information, Device logs, Operating systems, Browser information, Language, Launches, Number of sessions, Session duration, Scroll-to-page interactions, Mouse movements, Scroll position, Keypress events, Motion sensor events, Touch events, Video views, Clicks, Browsing history, Search history, Session statistics, Page views, Interaction events, Page events, Custom events, Application opens, First name, Last name, Contact info, Shipping address, Billing address, Physical address, Purchase history, Email address, Phone number, Data communicated while using the service, Company name, Date of birth, Gender, Geographic position, Profession, Screenshots, Workplace
Purposes:
- Spam and bots protection
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare, Inc., this Website
-
Employment related information
Personal Information collected or disclosed:
Email address, First name, Last name, Trackers, Usage data, Phone number, Profession, County, State, Country, Zip/postal code, Gender, Date of birth, City, Physical address, Company name, Website, Contact info, Shipping address, Billing address, Purchase history, Device information, Data communicated while using the service, Geographic position, Language, Screenshots, Workplace
Purposes:
- Contacting the User
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: this Website
Service providers or contractors: this Website
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
Data communicated while using the service, User content, Clicks, First name, Last name, Profile picture, Social media accounts, Page views, Interaction events, Email address, Usage data, Contact info, Shipping address, Billing address, Physical address, Purchase history, Phone number, Device information, City, Company name, Country, Date of birth, Gender, Geographic position, Language, Profession, Screenshots, Workplace
Purposes:
- Advertising
- Building and running this Website
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: GoDaddy.com, LLC, this Website
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.