Privacy Policy of contents.com

Owner and Data Controller

Contents S.p.A. - Via Paolo da Cannobio, 9, 20122, Milano MI - ITALY - VAT IT09559750964

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Tracker; Usage Data; email address; first name; last name; phone number; county; state; country; ZIP/Postal code; city; company name; website; physical address; payment info; billing address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; Data communicated while using the service; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; device information; username; password; field of activity; language; number of Users; session statistics; 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, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational 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.

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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• 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.

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.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 do so for the performance of 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 purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Tag Management, Contacting the User, Collection of privacy-related preferences, Interaction with support and feedback platforms, Handling payments, Remarketing and behavioural targeting, Displaying content from external platforms, Managing contacts and sending messages, User database management, Managing support and contact requests, Hosting and backend infrastructure, Interaction with live chat platforms, SPAM protection, Registration and authentication, Advertising, Registration and authentication provided directly by this Website, Communication and Traffic optimisation and distribution.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by this Website

This Website may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following: Access private data and Basic information.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Access to third-party accounts

  This type of service allows this Website to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorisation by the User.

  Facebook account access (Meta Platforms, Inc.)

  This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Access private data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Advertising

  This type of service allows User Data to be utilised 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 behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, 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.

  Outbrain (Outbrain Inc.)

  Outbrain is an advertising service provided by Outbrain Inc.

  Personal Data processed: Tracker; 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 CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

  Yandex (YANDEX, LLC)

  Yandex is an advertising service provided by YANDEX, LLC.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Russian Federation – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

• Analytics

  The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises 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 contextualise and personalise the ads of its own advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Ads conversion tracking (Google Ireland Limited)

  Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Analytics Advertising Reporting Features (Google Ireland Limited)

  Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Meta advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Analytics with anonymised IP (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises 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 contextualise and personalise the ads of its own advertising network.
  This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Analytics collected directly (this Website)

  This Website uses an internal analytics system that does not involve third parties.

  Personal Data processed: Usage Data.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the VCDPA

  LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

  LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website.

  Users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.

  Personal Data processed: device information; Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Cloudflare Web Analytics (Cloudflare Inc.)

  Cloudflare Web Analytics is an anonymised analytics service provided by Cloudflare Inc. that gives the Owner insight into the use of this Website by Users without needing to identify them. Further information may be found here and within the service's privacy policy.

  Personal Data processed: device information; language; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information; inferred information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Matomo (this Website)

  Matomo is an analytics software used by this Website to analyse data directly without the help of third parties.

  Personal Data processed: Trackers; Usage Data.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the VCDPA

  Meta Events Manager (Meta Platforms Ireland Limited)

  Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Website.

  Personal Data processed: Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  TikTok conversion tracking (TikTok Inc.)

  TikTok conversion tracking is an analytics and behavioural targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on this Website. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of this Website.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Google Analytics 4 (Google Ireland Limited)

  Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  In 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.

  Personal Data processed: browser information; number of Users; session statistics; Trackers; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Collection of privacy-related preferences

  This type of service allows this Website to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

  iubenda Cookie Solution (iubenda srl)

  The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information and in particular to the use of Cookies and other Trackers on this Website.

  Personal Data processed: Tracker.

  Place of processing: Italy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  iubenda Consent Solution (iubenda srl)

  The iubenda Consent Solution allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
  In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

  Personal Data processed: Data communicated while using the service; Tracker.

  Place of processing: Italy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Communication

  Website contentsads.com

  The policy also applies to the contentsads.com website

  This processing constitutes:

  • a sale according to the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

• 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: city; company name; country; county; email address; first name; last name; phone number; physical address; state; Usage Data; website; ZIP/Postal code.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  This processing constitutes:

  • a sale according to the VCDPA

  Contact form (this Website)

  By filling in the contact form with their Data, the User authorises 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 CCPA: identifiers; commercial information.

  This processing constitutes:

  • a sale according to the VCDPA

  Phone contact (this Website)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.

  Personal Data processed: phone number.

  Category of personal information collected according to CCPA: identifiers.

  This processing constitutes:

  • a sale according to the VCDPA

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Website to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Handling payments

  Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  Stripe

  Stripe is a payment service provided by Stripe Inc, Stripe Technology Europe Ltd or by Stripe Payments Ltd, depending on how the Owner manages the Data processing.

  Personal Data processed: billing address; email address; first name; last name; payment info; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data processed: billing address; email address; first name; last name; payment info; various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  Microsoft Azure (Microsoft Corporation)

  Microsoft Azure is a hosting service provided by Microsoft Corporation.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; Australia – Privacy Policy; Germany – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Canada – Privacy Policy; Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Zendesk Chat (Zendesk, Inc.)

  Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.

  Personal Data processed: Data communicated while using the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Interaction with support and feedback platforms

  This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Website.
  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.

  Zendesk Widget (Zendesk, Inc.)

  The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• 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; country; email address; first name; last name; phone number; physical address; Usage Data; various types of Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

  HubSpot Email (HubSpot, Inc.)

  HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

  Personal Data processed: email address; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

• 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).

  Zendesk (Zendesk, Inc.)

  Zendesk is a support and contact request management service provided by Zendesk 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 CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• Registration and authentication

  By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Google OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Facebook Authentication (Facebook Ireland Ltd)

  Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Facebook Oauth (Facebook Ireland Ltd)

  Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  Log In with PayPal (PayPal Inc.)

  Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• 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; field of activity; password; state; Usage Data; username; various types of Data.

  Category of personal information collected according to CCPA: identifiers; internet information.

• Remarketing and behavioural targeting

  This type of service allows this Website and its partners to inform, optimise 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 behavioural targeting activity.
  Some services offer a remarketing option based on email address lists.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  LinkedIn Website Retargeting (LinkedIn Corporation)

  LinkedIn Website Retargeting is a remarketing and behavioural targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

  TikTok Remarketing ( TikTok Information Technologies UK Limited )

  TikTok Remarketing is a remarketing and behavioural targeting service provided by TikTok Information Technologies UK Limited that connects the activity of this Website with the TikTok advertising network.

  Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: United Kingdom – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA
  • a sharing according to the CCPA
  • targeted advertising according to the VCDPA

• SPAM protection

  This type of service analyses the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information; inferred information.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralised fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA

• Traffic optimisation and distribution

  This type of service allows this Website to distribute their content using servers located across different countries and to optimise 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 optimisation 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 CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

• 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.

  HubSpot CRM (HubSpot, Inc.)

  HubSpot CRM is a User database management service provided by HubSpot, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

  HubSpot Lead Management (HubSpot, Inc.)

  HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes:

  • a sale according to the CCPA and the VCDPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• localStorage

  localStorage allows this Website to store and access data right in the User's browser with no expiration date.

• sessionStorage

  sessionStorage allows this Website to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• 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. Further details are provided in the dedicated section below.
• 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, under certain circumstances, 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, under certain circumstances, 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. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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 without providing any justification. 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. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses Trackers. To learn more, the User may consult the Cookie Policy.

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.

Information not contained in this policy

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.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

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.

Information for Californian consumers

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 provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).

Notice at collection

Categories of personal information collected, used, sold, or shared

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, commercial information, internet information and inferred information.

We have collected the following categories of sensitive personal information: payment info, payment info, username and password

We will not collect additional categories of personal information without notifying you.

Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it

You have the right to request that we limit the 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.

We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.

Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.

To fully exercise your right to limit the use or disclosure of your sensitive personal information 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 information collected from you in connection with the submission of your request solely for the purposes of complying with the request.

Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.

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. 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 minor 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.

Information for Virginia consumers

This part 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”).

The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

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, 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.
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.

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 relates 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 minor 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.

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• your consent to the relevant processing activities;
• compliance with a legal or regulatory obligation that lies with us;
• the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
• studies conducted by research entities, preferably carried out on anonymised personal information;
• the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
• the exercising of our rights in judicial, administrative or arbitration procedures;
• protection or physical safety of yourself or a third party;
• the protection of health – in procedures carried out by health entities or professionals;
• our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
• credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

• obtain confirmation of the existence of processing activities on your personal information;
• access to your personal information;
• have incomplete, inaccurate or outdated personal information rectified;
• obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
• obtain information on the possibility to provide or deny your consent and the consequences thereof;
• obtain information about the third parties with whom we share your personal information;
• obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
• obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
• revoke your consent at any time;
• lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
• oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
• request clear and adequate information regarding the criteria and procedures used for an automated decision; and
• request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
• when the transfer is necessary to protect your life or physical security or those of a third party;
• when the transfer is authorised by the ANPD;
• when the transfer results from a commitment undertaken in an international cooperation agreement;
• when the transfer is necessary for the execution of a public policy or legal attribution of public service;
• when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.