Privacy e Cookie Policy

Privacy and Cookie Policy of Hypn Vault

This Website collects certain Personal Data of its Users.

Data Controller

Hypn Records - Limited Liability Company Via Enrico Fermi, 10
Bellaria-Igea Marina (RN)
47814

VAT number: 04539620403
Business Register Rimini REA: RN-420165

Email address of the Data Controller: hypnrecords@pec.it Types of Data Collected

Among the Personal Data collected by this Website, independently or through third parties, are: email; name; Cookies; Usage Data; Data communicated during the use of the service; phone number; surname; date of birth; address; username; password; geographic location; nation; city; billing address; shipping address; payment information; device information; answers to questions; clicks; keypress events; motion sensor events; mouse movements; relative scrolling position; touch events; purchase history; approximate location; number of Users; session statistics; latitude (of the city); longitude (of the city); browser information; unique device identifiers for advertising purposes (Google Advertiser ID or IDFA identifier, for example); gender; VAT number; company name; profession; profile picture; screen; workplace; postal code; state; User ID; Data communicated to use the Service; Universal Unique Identifier (UUID).

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the data collection itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.

If not otherwise specified, all the Data required by this Website is mandatory. If the User refuses to communicate them, this Website may not be able to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequences on the availability of the Service or its operation.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller. The possible use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website and guarantees that they have the right to communicate or disseminate them, freeing the Data Controller from any responsibility towards third parties.

Methods and location of data processing Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Processing is carried out using computers and/or IT tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administration personnel) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of processing

The Data Controller processes Personal Data concerning the User in the event one of the following conditions exists:

The User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be allowed to process Personal Data without the User's consent or another legal basis specified below until the User objects ("opt-out") to such processing. However, this is not applicable if the processing of Personal Data is regulated by European legislation relating to the protection of Personal Data;
Processing is necessary for the performance of a contract with the User and/or for pre-contractual measures;

Processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
Processing is necessary for the legitimate interests pursued by the Data Controller or by third parties.

However, it is always possible to request the Data Controller to clarify the specific legal basis for each processing and, in particular, to specify whether the processing is based on law, required by a contract, or necessary to conclude a contract.

Location

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information about the location of the processing, the User can refer to the section regarding details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as the United Nations (UN), as well as the security measures taken by the Data Controller to protect the Data.

The User can verify whether one of the described transfers takes place by examining the section of this document regarding details on the processing of Personal Data or by requesting information from the Data Controller using the contact details provided at the beginning.

Retention Period

The Data is processed and stored for the time required by the purposes for which it was collected. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the completion of such contract.
Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until the satisfaction of such interests. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Additionally, the Data Controller may be obliged to retain the Personal Data for a longer period in compliance with a legal obligation or upon the order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiration of this period, the right to access, delete, rectify, and the right to data portability cannot be exercised anymore.

Purposes of Data Processing

The User's Data is collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any fraudulent or malicious activities, as well as for the following purposes: Contacting the User, Payment Management, Registration and Authentication, Statistics, Hosting and Backend Infrastructure, Interaction with Social Networks and External Platforms, Productivity-related activity management, Displaying content from external platforms, Tag Management, Content and Functionality Performance Testing (A/B testing), Platform and hosting services, SPAM protection, Advertising, Remarketing, and Behavioral Targeting, Location-based interactions, Data Collection and Online Survey Management, and Marketing.

For detailed information on the purposes of processing and the Personal Data processed for each purpose, the User can refer to the section "Details on the processing of Personal Data."

Details on the Processing of Personal Data

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

Contacting the User

Mailing list or newsletter (this Website)

By registering for the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information related to this Website, may be transmitted. The User's email address may also be added to this list as a result of registering for this Website or after making a purchase.

Personal Data Processed: email; name.
Category of personal information collected under CCPA: identifiers. This type of processing constitutes:

a sale under CCPA and VCDPA
a disclosure under CCPA
targeted advertising according to VCDPA

Contact Form (this Website)

By filling in the contact form with their Data, the User consents to its use for responding to requests for information, quotes, or any other kind of request as indicated by the form's header.

Personal Data Processed: surname; email; name.
Category of personal information collected under CCPA: identifiers. This type of processing constitutes:

a sale under CCPA and VCDPA
a disclosure under CCPA
targeted advertising according to VCDPA

Contact via Phone (this Website)

Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Website, as well as to fulfill support requests.

Personal Data Processed: phone number.
Category of personal information collected under CCPA: identifiers. This type of processing constitutes:

a sale under CCPA and VCDPA

Payment Management

Unless otherwise specified, this Website processes all payments through credit card, bank transfer, or other means via external payment service providers. In general, and unless otherwise stated, Users are requested to provide payment details and personal information directly to these payment service providers.

This Website is not involved in the collection and processing of such information: it will instead receive a notification from the respective payment service provider about the successful payment.

PayPal (Paypal)

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

Personal Data Processed: various types of Data as specified in the privacy policy of the service. Location of processing: Refer to PayPal Privacy Policy.

Category of personal information collected under CCPA: information about the internet.

PayPal Carrier Payments (Paypal)

PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile operator.

Personal Data Processed: phone number; various types of Data as specified in the privacy policy of the service.

Location of processing: Refer to PayPal Privacy Policy.
Category of personal information collected under CCPA: identifiers; information about the internet.

PayPal Payments Hub (Paypal)

PayPal Payments Hub is a payment service provided by PayPal Inc.

Personal Data Processed: various types of Data as specified in the privacy policy of the service. Location of processing: Refer to PayPal Privacy Policy.
Category of personal information collected under CCPA: information about the internet.

Amazon Payments (Amazon)

Amazon Payments is a payment service provided by Amazon.com, Inc., which allows Users to make online payments using their Amazon credentials.

Personal Data Processed: surname; purchase history; usage data; email; billing address; shipping address; payment information; name; phone number; password; tracking tools; username; various types of Data as specified in the privacy policy of the service.

Location of processing: Refer to Amazon Privacy Policy.
Category of personal information collected under CCPA: identifiers; commercial information; information about the internet.

This type of processing constitutes:

a sale under CCPA and VCDPA
a disclosure under CCPA
targeted advertising according to VCDPA

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phone.

Personal Data Processed: surname; purchase history; usage data; email; billing address; shipping address; payment information; name; phone number; tracking tools; various types of Data as specified in the privacy policy of the service.

Location of processing: United States – Privacy Policy.
Category of personal information collected under CCPA: identifiers; commercial information; information about the internet.

This type of processing constitutes:

a sale under CCPA and VCDPA
a disclosure under CCPA
targeted advertising according to VCDPA

Google Pay

Google Pay is a payment service provided by either Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing. It allows Users to make online payments using their Google credentials.

Personal Data Processed: surname; purchase history; usage data; email; billing address; shipping address; payment information; name; phone number; tracking tools; various types of Data as specified in the privacy policy of the service.

Location of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under CCPA: identifiers; commercial information; information about the internet.

This type of processing constitutes:

a sale under CCPA and VCDPA
a disclosure under CCPA
targeted advertising according to VCDPA

Tag Management

This type of service helps the Data Controller manage the tags or scripts used on this Website centrally. The use of these services involves the flow of User Data through them and, if applicable, their retention.

Google Tag Manager (Google Ireland Limited)

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

Personal Data Processed: usage data.
Location of processing: Ireland – Privacy Policy.
Category of personal information collected under CCPA: information about the internet.

Data Collection and Online Survey Management

This type of service allows this Website to manage the creation, implementation, administration, distribution, and analysis of online forms and surveys to collect, save, and reuse User Data in responding to them.
The Personal Data collected depends on the information requested and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services mentioned in this privacy policy to allow the Data Controller to perform subsequent actions with the processed Data - for example, managing contacts, sending messages, statistics, advertising, and payment processing.

Lead Ads on Facebook (Meta)

Lead Ads on Facebook is an advertising and data collection service provided by Meta Platforms, Inc., or Meta Platforms Ireland Limited, depending on how the Data Controller manages the Data, allowing Users to see advertisements in the form of pre-filled forms with their Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of ad, Users may be asked to provide additional information.

Submitting the form implies the collection and processing of this Data by the Data Controller under this privacy policy and only for the specific purpose indicated in the form and/or within this privacy policy, where specified.

Users may exercise their rights at any time, including the right to withdraw consent to the processing of their Data, as specified in the section containing information on User rights in this privacy policy.

Personal Data Processed: ZIP code; city; surname; date of birth; Data communicated during the use of the service; usage data; email; physical address; country; name; phone number; profession; business name; gender; state; tracking tools.

Location of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected under CCPA: identifiers; commercial information; information about the internet; employment-related information.

This type of processing constitutes:

a sale under CCPA and VCDPA

Productivity-related Activity Management

This type of service helps the Data Controller manage tasks, work projects, and overall productivity-related activities. When using this type of service, User Data will be processed and may be retained, depending on the purpose of the respective activity.
These services may be integrated with a wide range of third-party services mentioned in this privacy policy to allow the Data Controller to import or export the necessary Data for the corresponding activity.

Gmail (Google Ireland Limited)

Gmail is a service that handles email communications provided by Google Ireland Limited. Email communications are not analyzed by Google for advertising purposes. Additionally, Google does not collect or use data within this service for advertising purposes in any other way.

Personal Data processed: city; surname; Cookies; date of birth; email; address; country; name; phone number; password; geographical location; username.

Processing location: Ireland – Privacy Policy.
Category of personal information collected under CCPA: identifiers; internet information; geolocation data.

Google Docs

Google Docs is an online text editing and workflow management service provided by either Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of data.

Personal Data processed: city; surname; date of birth; Data communicated during the use of the service; Usage Data; email; profile picture; physical address; device information; name; phone number; VAT number; geographical location; profession; company name; screen; workplace address; gender; Tracking Tools; username.

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected under CCPA: identifiers; commercial information; internet information; geolocation data; sensor-based information; employment-related information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Google Sheets (Google LLC)

Google Sheets is an online spreadsheet editing and workflow management service provided by Google LLC.

Personal Data processed: city; surname; date of birth; Data communicated during the use of the service; Usage Data; email; physical address; device information; country; name; phone number; VAT number; geographical location; company name; Tracking Tools; username.

Processing location: United States – Privacy Policy.
Category of personal information collected under CCPA: identifiers; commercial information; internet information; geolocation data.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Hosting and Backend Infrastructure

This type of service functions to host data and files that enable this Website to operate, distribute content, and provide an infrastructure ready to use to deliver specific functionalities of this Website.

iubenda Consent Solution (iubenda srl)

The Consent Solution offered by iubenda allows for the storage and consultation of records related to the consent and preferences expressed by end users regarding the processing of their Personal Data.

Personal Data processed: Data communicated during the use of the service; Tracking Tool.

Processing location: Italy – Privacy Policy.
Category of personal information collected under CCPA: internet information.

Google Cloud Storage

Google Cloud Storage is a hosting service provided by either Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of data.

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

Processing location: United States – Privacy Policy.
Category of personal information collected under CCPA: identifiers.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Interaction with Social Networks and External Platforms

This type of service allows for interactions with social networks or other external platforms directly from the pages of this Website. Interactions and information acquired by this Website are subject to the privacy settings of the User for each social network.

This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to disconnect from the respective services to ensure that the data processed on this Website is not reconnected to the User's profile.

PayPal Button and Widget (Paypal)

The PayPal Button and Widget are services for interacting with the PayPal platform, provided by PayPal Inc.

Personal Data processed: Cookie; Usage Data.

Processing location: Consult Paypal's privacy policy – Privacy Policy.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:
a sale under CCPA and VCDPA

Location-Based Interactions

Geolocation (this Website)

This Website may collect, use, and share data related to the User's geographic location to provide location-based services.

Most browsers and devices provide default tools to deny geolocation tracking. If the User has expressly authorized this possibility, this Website may receive information about their actual geographic location.

Personal Data processed: approximate location; geographic location.

Category of personal information collected under CCPA: geolocation data.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Marketing

Omnisend - Email & SMS Marketing

Data collected: name, email, phone number, device.
Privacy policy: https://www.omnisend.com/privacy/

Address: Verkių g. 25C-1, LT-08223 Vilnius, Republic of Lithuania

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Okendo - Reviews

Data collected: name, email, previous purchases, phone number.
Privacy policy: https://www.okendo.io/privacy-policy/

Location: Okendo Pty Ltd ACN 165 005 989, Australia

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Conversion Bear

Data collected: name, email, previous purchases, phone number.
Privacy policy: https://www.conversionbear.com/privacy-policy

Location: Tel Aviv

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Smile - Rewards

Data collected: name, email, previous purchases, phone number.
Privacy policy: https://smile.io/privacy-policy

Location: PO Box 33042 Ira Needles Waterloo, ON, N2T 2M9 Canada

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

SPAM Protection

This type of service analyzes the traffic of this Website, which may contain Personal Data of Users, in order to filter it from parts of traffic, messages, and content recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of data.

The use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.

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

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected under CCPA: internet information; indirect information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Advertising

This type of service allows the use of User Data for commercial communication purposes. These communications are displayed on this Website in the form of banners and other advertising formats, even in relation to the User's interests.

This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.

Some of the services listed below may use Tracking Tools to identify the User or use behavioral retargeting techniques, which means displaying personalized advertisements based on the User's interests and behavior, even outside this Website. For more information, we recommend checking the privacy policies of the respective services. Generally, services of this kind offer the option to disable such tracking. In addition to any opt-out features provided by any of the services listed in this document, Users can learn more about opting out of interest-based advertising in the relevant section "How to disable interest-based advertising" in this document.

Czech Publisher Exchange (Czech Publisher Exchange z.s.p.o.)

Czech Publisher Exchange is an advertising service provided by Czech Publisher Exchange z.s.p.o.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: Czech Republic – Privacy Policy.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Google Ads Similar Audiences

Google Ads Similar Audiences is an advertising and behavioral targeting service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of data. It uses Google Ads Remarketing Data to show advertisements to Users with behaviors similar to those of other Users who are already on the remarketing list due to their previous use of this Website. Based on this data, personalized ads will be shown to Users suggested by Google Ads Similar Audiences.

Users who do not wish to be included in similar audience segments can choose not to participate and disable the use of advertising Tracking Tools by visiting the Google Ads Settings.

For an understanding of Google's use of Data, please refer to Google's partner policies.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Meta Audience Network

Meta Audience Network is an advertising service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of data. To understand Meta's data usage, please refer to Meta's data policy.

To enable the functioning of Meta Audience Network, this Website may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for OS) or similar technologies to cookies. One of the ways in which Audience Network delivers advertisements to the User is also through the use of the User's advertising preferences. Users can control the sharing of their advertising preferences within the Facebook Ad Settings.

Users can opt-out of some Audience Network targeting features through their device settings. For example, they can modify the advertising settings available for mobile devices or follow applicable instructions for Audience Network within this privacy policy.

Personal Data processed: Usage Data; unique identifiers for advertising purposes (Google Advertiser ID or IDFA, for example); Tracking Tools.

Processing location: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Meta Similar Audience

Meta Similar Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of data. It uses Data collected through Meta Custom Audience service to show advertisements to Users with behaviors similar to Users who are already in a Custom Audience list based on their previous use of this Website or their interaction with relevant content through Meta applications and services.

Based on this data, personalized ads will be shown to Users suggested by Meta Similar Audience.

Users can choose not to use Meta's Tracking Tools for ad personalization by visiting this opt-out page.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Registration and Authentication

By registering or authenticating, the User allows this Website to identify them and give them access to dedicated services.
Depending on what is described below, registration and authentication services may be provided with the help of third parties. If this occurs, this Website may access some Data stored by the third-party service used for registration or identification.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; for more information, please refer to the description of each service.

Log In with PayPal (Paypal)

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

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Processing location: Refer to PayPal's privacy policy – Privacy Policy.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA

Remarketing and Behavioral Targeting

This type of services allows this Website and its partners to communicate, optimize, and serve advertisements based on the User's past use of this Website.
This activity is facilitated by tracking Usage Data and using Tracking Tools to collect information that is then transferred to partners managing remarketing and behavioral targeting activities.

Some services offer a remarketing option based on email address lists.
Generally, services of this kind offer the option to disable such tracking. In addition to any opt-out features provided by any of the services listed in this document, Users can learn more about opting out of interest-based advertising in the relevant section "How to disable interest-based advertising" in this document.

Facebook Remarketing

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of data. It connects the activity of this Website with the Meta advertising network.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA, a sharing under CCPA, targeted advertising according to VCDPA

Remarketing Google Ads

Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing. It connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

For an understanding of Google's use of data, please refer to Google's partner policies.

Users can choose not to use Google's Tracking Tools for ad personalization by visiting the Google Ads Settings.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Meta Custom Audience

Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the data processing. It connects the activity of this Website with the Meta advertising network.

Users can choose not to use Meta's Tracking Tools for ad personalization by visiting this opt-out page.

Personal Data processed: email; Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Remarketing TikTok (TikTok Information Technologies UK Limited)

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

Personal Data processed: Usage Data; unique identifiers for advertising purposes (Google Advertiser ID or IDFA, for example); device information; Tracking Tools.

Processing location: United Kingdom – Privacy Policy.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Platform and Hosting Services

These services aim to host and operate key components of this Website, making it possible to deliver this Website from a single platform. These platforms provide the Data Controller with a wide range of tools such as analytical tools for user registration management, comment and database management, e-commerce, payment processing, etc. The use of such tools involves the collection and processing of Personal Data.

Some of these services operate through servers located in different geographical locations, making it difficult to determine the exact location where Personal Data is stored.

Shopify

Shopify is a platform provided by Shopify Inc. that allows the Data Controller to develop, operate, and host an e-commerce dedicated website.

Personal Data processed: last name; Usage Data; email; billing address; shipping address; payment information; device information; name; phone number; Tracking Tools.

Processing location: Canada – Privacy Policy; Ireland – Privacy Policy.

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

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Statistics

The services in this section allow the Data Controller to monitor and analyze traffic data and track user behavior.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected to track and examine the use of this Website, compile reports, and share them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads within its advertising network.

Personal Data processed: Cookies; Usage Data.

Processing location: Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA

Google Analytics with anonymized IP (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected to track and examine the use of this Website, compile reports, and share them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads within its advertising network.

This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address of Users within the member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States.

Personal Data processed: Cookies; Usage Data.

Processing location: Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA

Google Ads Conversion Tracking

Google Ads Conversion Tracking is a statistics service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing. It connects data from the Google Ads advertising network with actions performed within this Website.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Google Analytics 4

Google Analytics is a statistics service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing ("Google"). Google uses the Personal Data collected to track and examine the use of this Website, compile reports, and share them with other services developed by Google.

Google may use Personal Data to contextualize and personalize ads within its advertising network. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is stored in any data center or server. For more information, you can consult Google's official documentation.

Personal Data processed: city; Usage Data; browser information; device information; latitude (city); longitude (city); number of Users; session statistics; Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: identifiers; internet information; geolocation data.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Google Analytics Advertising Reporting Features

Google Analytics on this Website has enabled advertising reporting features that collect additional information from the DoubleClick cookie (web activity) and the advertising ID of the device (app activity). This allows the Data Controller to analyze specific data related to User behaviors and interests (Traffic Data and User interaction data with ads) and, if enabled, demographics (information about age and gender).

Users can choose not to use Google cookies by visiting Google's Ad Settings.

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

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA
a sharing under CCPA
targeted advertising according to VCDPA

Google Analytics Demographics and Interests Reports

Google Analytics Demographics and Interests Reports is an advertising reporting feature that makes demographic and interest data available within Google Analytics for this Website (demographic data refers to data about age and gender).

Users can choose not to use Google cookies by visiting Google's Ad Settings.

Personal Data processed: unique identifiers for advertising purposes (Google Advertiser ID or IDFA, for example); Tracking Tools.

Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

a sale under CCPA and VCDPA, a sharing under CCPA, targeted advertising according to VCDPA

Conversion Tracking of Meta Ads (Meta Pixel)

The conversion tracking of Meta Ads (Meta Pixel) is a statistics service provided by Meta Platforms, Inc. or Meta Platforms Ireland Limited, depending on how the Data Controller manages the data processing. It connects data from the Meta advertising network with actions performed within this Website. The Meta Pixel tracks conversions that can be attributed to Facebook, Instagram, and Audience Network advertisements.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

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

Meta Events Manager

The Meta Events Manager is a statistics service provided by Meta Platforms Ireland Limited or Meta Platforms, Inc., depending on how the Data Controller manages the data processing. By integrating the Meta Pixel, the Meta Events Manager can provide the Data Controller with information about traffic and interactions on this Website.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: Ireland – Privacy Policy – Opt out; United States – Privacy Policy – Opt out.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

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

Conversion Tracking of TikTok (TikTok Inc.)

The conversion tracking of TikTok is a statistics service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed within this Website. The TikTok Pixel tracks conversions that can be attributed to TikTok advertisements and allows targeting groups of Users based on their previous use of this Website.

Personal Data processed: Usage Data; unique identifiers for advertising purposes (Google Advertiser ID or IDFA, for example); device information; Tracking Tools.

Processing location: United States – Privacy Policy.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

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

YouTube Analytics and Reporting API

YouTube Analytics and Reporting API is a statistics service related to video content provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing.

Through this service, this Website may collect Data directly or indirectly about Users or from Users' devices, also through the use of Tracking Tools. Users can limit such access to their Data through the security settings page provided by Google. Users can contact the Data Controller at any time to request further information about privacy settings through the contact details provided in this document.

Data collected through the Service may also be used to help third parties display personalized advertising based on interests. Users can choose not to receive such personalized advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: data communicated during the use of the service; data communicated for the purpose of using the Service; Usage Data; User ID; device information; Tracking Tools.

Processing location: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

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

YouTube Video Widget

YouTube Video Widget is a video content display service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing. It allows this Website to integrate such content within its pages.

Personal Data processed: Usage Data; Tracking Tools.

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected under CCPA: internet information.

This type of processing constitutes:

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

YouTube Video Widget (Advanced Privacy Mode)

YouTube Video Widget (Advanced Privacy Mode) is a video content display service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the data processing. It allows this Website to integrate such content within its pages. This widget is set up in a way that YouTube does not save information and cookies regarding Users on this Website unless they play the video.

Personal Data processed: Usage Data; Universal Unique Identifier (UUID); Tracking Tools.

Processing location: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected under CCPA: identifiers; internet information.

This type of processing constitutes:

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

Information on How to Disable Interest-Based Advertisements

In addition to any opt-out function provided by any of the services listed in this document, Users can learn more about disabling interest-based advertisements in the relevant section of the Cookie Policy.

Additional Information on Data Processing

Legal Defense

The User's Personal Data may be used by the Data Controller in court or in the stages leading to possible legal action arising from improper use of this Website or the related services by the User.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Specific Information

Upon User's request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific services, or the collection and processing of Personal Data.

System Logs and Maintenance

For operation and maintenance purposes, this Website and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User's IP address.

Information Not Contained in this Policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to "Do Not Track" Requests

This Website does not support "Do Not Track" requests. To find out if any of the third-party services used support them, Users are encouraged to check the respective privacy policies.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if technically and legally feasible, by sending a notice to Users through any contact information available to the Data Controller. Therefore, it is advisable to consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes affect processing activities whose legal basis is consent, the Data Controller will collect new consent from the Users, if required.

Information for California Consumers

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the company that manages this website and, if applicable, by its parent company, subsidiaries, and affiliates (collectively referred to as "we", "us", "our").

The provisions contained in this section apply to all Users (hereinafter referred to as "you", "your") who are California residents, USA, under the "California Consumer Privacy Act of 2018" (CCPA), as amended by the "California Privacy Rights Act" (CPRA) and subsequent regulations. For such consumers, these provisions replace any divergent or conflicting provisions contained in the privacy policy.

In this section, the terms "personal information" (and "sensitive personal information") are used as defined in the California Consumer Privacy Act (CCPA).

Notice at Collection

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

In this section, we summarize the categories of personal information that we have collected, used, sold, or disclosed, and the purposes thereof. You can read the details of these activities in the section entitled "Detailed Information on Data Processing" in this document.

Information We Collect: Categories of personal data we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information, geolocation data, sensory data, employment-related information, and inferences.

We have collected the following categories of sensitive personal data: usernames, passwords, payment information, usernames, passwords, payment information, usernames, VAT numbers, payment information, usernames, and VAT numbers.

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

Your right to limit the use or disclosure of your sensitive personal data 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 what is necessary to perform services or provide goods, as reasonably expected of an average consumer.

We may also use your sensitive personal information to fulfill specific purposes required by law (such as, but not limited to, helping ensure safety and security; undertaking activities to verify or maintain quality or safety of our service) and as authorized by regulations.

Outside of the specific purposes mentioned above, you have the right to freely request at any time that your sensitive personal information not be used or disclosed. This means that every time you ask us to stop using your sensitive personal information, we will comply with your request and 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 data, 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.

The personal information collected from the user in relation to the submission of the request will be used solely to fulfill the request itself.

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

What are the purposes for which we use your personal data?

We may use the user's personal data to enable the operational functioning of the website and its features ("business purposes").

of this website and its features ("business purposes"). In these cases, the user's personal information will be treated as necessary and proportionate to the commercial purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal data for other purposes, such as for commercial purposes (as indicated in the "Detailed Information on Personal Data Processing" section within this document), as well as to comply with the law and defend our rights before the competent authorities if our rights and interests are threatened or if we suffer actual damage.

We will not process your data for unforeseen or incompatible purposes with those originally communicated without your consent.

How long do we retain your personal information?

Unless otherwise specified in the "Detailed Information on Personal Data Processing" section, we will not retain your personal information for longer than reasonably necessary for the purpose or purposes for which it was collected.

How do we collect information: what are the sources of the personal information we collect?

We collect the aforementioned categories of personal information, directly or indirectly, from you when you use this website.

For example, you directly provide your personal data when you submit requests through the forms on the Site. Personal data is also provided indirectly when you browse this website, as personal information is observed and collected automatically.

Finally, we may collect your personal data from third parties who collaborate with us in relation to the Service or the operation of this Application and its features.

How we use the collected information: disclosure of your personal data to third parties for commercial purposes

For our purposes, "third party" means a person who is not one of the following: a service provider or contractor, as defined by the CCPA.

We disclose your personal data to the third parties listed in detail in the section entitled "Detailed Information on Personal Data Processing" within this document. These third parties are grouped and categorized according to the different purposes of the processing.

Sale or sharing of your personal data

For our purposes, the term "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 occur whenever an application handles advertisements, or performs statistical analyses on traffic or views, or simply because it uses tools like social network plugins and the like.

For our purposes, "sharing" means any "sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, electronically, or by any 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 on behalf of the business where no money is exchanged," as defined by the CCPA.

Please note that the exchange of personal information with a service provider under a written contract that meets the requirements established 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 data and the methods to exercise it

We sell or share your personal data with the third parties listed in detail in the section entitled "Detailed Information on Personal Data Processing" within this document. These third parties are grouped and categorized according to the different purposes of the processing.

You have the right to opt-out of the sale or sharing of your personal data. This means that if you ask us to stop selling or sharing your personal data, we will comply with 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 wish to submit requests to opt-out of the sale or sharing of personal information through a user-enabled universal privacy control, such as the Global Privacy Control ("GPC"), you are free to do so, and we will comply with such request. The GPC consists of a setting or extension of the browser or mobile device and acts as a mechanism that websites can use to signal that they support the GPC signal. If you wish to use the GPC, you can download and activate it through a compliant browser or browser extension. Further information on downloading GPC is available here.

The personal information collected from the user in relation to the submission of the opt-out request will be used solely to fulfill the opt-out request.

Once the user has opted out, we are required to wait at least 12 months before asking if they have changed their mind.

What are the purposes for which we use your personal data?

We may use your personal information to enable the operational functioning of this website and its features ("business purposes"). In these cases, your personal information will be treated as necessary and proportionate to the commercial purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal data for other purposes, such as for commercial purposes (as indicated in the "Detailed Information on Personal Data Processing" section within this document), as well as to comply with the law and defend our rights before the competent authorities if our rights and interests are threatened or if we suffer actual damage.

We will not process your data for unforeseen or incompatible purposes with those originally communicated without your consent.

How long do we retain your personal information

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How long do we retain your personal information?

Unless otherwise specified in the "Detailed Information on Personal Data Processing" section, we will not retain your personal information for longer than reasonably necessary for the purpose or purposes for which it was collected.

How do we collect information: what are the sources of the personal information we collect?

We collect the aforementioned categories of personal information, directly or indirectly, from you when you use this website.

For example, you directly provide your personal data when you submit requests through the forms on the Site. Personal data is also provided indirectly when you browse this website, as personal information is observed and collected automatically.

Finally, we may collect your personal data from third parties who collaborate with us in relation to the Service or the operation of this Application and its features.

How we use the collected information: disclosure of your personal data to third parties for commercial purposes

For our purposes, "third party" means a person who is not one of the following: a service provider or contractor, as defined by the CCPA.

We disclose your personal data to the third parties listed in detail in the section entitled "Detailed Information on Personal Data Processing" within this document. These third parties are grouped and categorized according to the different purposes of the processing.

Sale or sharing of your personal data

For our purposes, the term "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 occur whenever an application handles advertisements, performs statistical analyses on traffic or views, or simply uses tools like social network plugins.

For our purposes, "sharing" means any "sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, electronically, or by any 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 on behalf of the business where no money is exchanged," as defined by the CCPA.

Please note that the exchange of personal information with a service provider under a written contract that meets the requirements established 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 data and the methods to exercise it

We sell or share your personal data with the third parties listed in detail in the section entitled "Detailed Information on Personal Data Processing" within this document. These third parties are grouped and categorized according to the different purposes of the processing.

You have the right to opt-out of the sale or sharing of your personal data. This means that if you ask us to stop selling or sharing your personal data, we will comply with 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 wish to submit requests to opt-out of the sale or sharing of personal information through a user-enabled universal privacy control, such as the Global Privacy Control ("GPC"), you are free to do so, and we will comply with such request. The GPC consists of a setting or extension of the browser or mobile device and acts as a mechanism that websites can use to signal that they support the GPC signal. If you wish to use the GPC, you can download and activate it through a compliant browser or browser extension. Further information on downloading GPC is available here.

The personal information collected from the user in relation to the submission of the opt-out request will be used solely to fulfill the opt-out request.

Once the user has opted out, we are required to wait at least 12 months before asking if they have changed their mind.

What are the purposes for which we use your personal data?

We may use your personal information to enable the operational functioning of this website and its features ("business purposes"). In these cases, your personal information will be treated as necessary and proportionate to the commercial purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal data for other purposes, such as for commercial purposes (as indicated in the "Detailed Information on Personal Data Processing" section within this document), as well as to comply with the law and defend our rights before the competent authorities if our rights and interests are threatened or if we suffer actual damage.

We will not process your data for unforeseen or incompatible purposes with those originally communicated without your consent.

How long do we retain your personal information?

Unless otherwise specified in the "Detailed Information on Personal Data Processing" section, we will not retain your personal information for longer than reasonably necessary for the purpose or purposes for which it was collected.

Your rights under the California Consumer Privacy Act and how to exercise them

Right to access personal information: right to know and portability

You have the right to request that the following be disclosed:

The categories of personal information we collect about you; The sources from which we collect personal information; 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 being sold or shared and to whom. Specifically, you have the right to request two separate lists from us revealing:

The categories of personal information we have 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 we have disclosed about you for a business purpose and the categories of recipients to whom the personal information was disclosed for a business purpose.

The above disclosure will be limited to personal information collected or used in the last 12 months.

If the response is provided electronically, the information attached will be "portable," meaning it will be provided in a readily usable format to allow you to transmit the information to another entity without hindrance, where technically feasible.

Right to request the deletion of your personal data

You have the right to request the deletion of your personal information, subject to exceptions provided by law (e.g., if the information is used to identify and rectify errors on the website, detect security incidents, and protect against fraudulent or illegal activities, exercise certain rights, etc.)

If no legal exception applies, upon exercising your right, we will delete your personal information and instruct all our service providers and third parties to whom we have sold or shared personal information to do so, provided that it is technically feasible and does not entail a disproportionate effort.

Right to correct inaccurate personal information

You have the right to request the correction of any inaccurate personal information we hold about you, taking into account the nature of the personal information and the purposes of processing the personal information.

Right to opt-out of the 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 the use or disclosure of your sensitive personal information be limited.

Right to non-discrimination as a result of opting out or exercising other rights (right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not deny you goods or services, charge you a different price, or provide you with a different level or quality of goods or services just because you have exercised your consumer privacy rights.

However, if you refuse to provide us with your personal data or ask us to delete or stop selling your personal data, and such personal data or sale is necessary to provide you with goods or services, we may not be able to complete the transaction.

To the extent permitted by law, we may offer you promotions, discounts, and other offers in exchange for the collection, retention, or sale of your personal data, provided that the financial incentive offered is reasonably related to the value of your personal data.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request by contacting us through the contact details provided in this document.

In order to respond to your request, we need to know who you are. Therefore, you can exercise the above rights only by submitting a verifiable request that must:

Provide sufficient information that allows us to reasonably verify that 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 confirm that the personal information in our possession is indeed yours.

To make a verifiable request as a consumer, you are not required to create an account with us. The personal information collected from you in connection with verifying your request will be used solely for the purposes of verification and will not be further disclosed, retained for longer than necessary for the purposes of verification, or used for purposes unrelated to the verification process.

If you are unable to 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 of 2 requests within a 12-month period.

How and when we will handle your request

We will confirm the 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. If we need more time, we will explain the reasons and the time required. Please note that we may take up to 90 days to fulfill your request.

Our disclosures will cover the preceding 12-month period. Only with regard to personal data collected starting January 1, 2022, you have the right to request disclosure beyond the 12-month period, and we will provide it unless it is impossible or involves a disproportionate effort.

If your request is denied, we will explain the reasons for the denial.

We will not charge any fee to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to comply with the request. In either case, we will communicate our choices and explain the reasons.

Information for Virginia Consumers

This part of the document supplements and completes the information contained in the rest of the privacy notice and is provided by the data controller operating this Application and, if applicable, its parent, subsidiaries, and affiliates (for purposes of this section referred to collectively as "we," "us," "our").

The provisions contained in this section apply to all Users (hereinafter referred to as "you," "your") who are consumers residing in the Commonwealth of Virginia, as defined by the "Virginia Consumer Data Protection Act" (the "VCDPA"), and for such consumers, these provisions supersede any other divergent or conflicting provisions contained in the privacy notice.

In this section, the terms "personal data" (and "sensitive data") are used as defined in the VCDPA.

Categories of Personal Data Processed

In this section, we summarize the categories of personal data we have processed and their respective purposes. You can read in detail about these activities in the section titled "Detailed Information on Personal Data Processing" within this document.

Categories of Personal Data Collected

We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, sensory information, employment-related information, and inferred information.

With your consent, we collect the following categories of sensitive data: VAT number and VAT number.

You are free to give, deny, or withdraw your consent to the processing of sensitive data at any time by using the contact details provided in this document or via the privacy choices link provided on this website.

We will not collect additional categories of personal data without informing you.

Reasons for Processing Your Personal Data

To understand why we process your personal data, you can read the sections titled "Detailed Information on Personal Data Processing" and "Purposes of Processing" within this document.

We will not process your data for unforeseen or incompatible purposes with those originally communicated without your consent.
You are free to give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the collected data: Sharing 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 Personal Data Processing" within this document. These third parties are grouped and categorized based on different processing purposes.
For our purposes, "third parties" refer to "any natural or legal person, public authority, agency, or body other than the consumer, the controller, the processor, or an affiliate of the controller or processor," as defined by the VCDPA.

Sale of your personal data

For our purposes, the term "sale" means any "exchange of personal data for monetary consideration by us to third parties," as defined by the VCDPA.
Please note that, under the VCDPA, the disclosure of personal data to a processor on behalf of a controller does not constitute a sale.

As specified in the section "Detailed Information on Personal Data Processing" of this document, our use of your personal data may be considered a sale under the VCDPA.

Your right to opt-out of the sale of your personal data and how to exercise that right

You have the right to opt-out of the sale of your personal data. This means that whenever you ask us to stop selling your data, we will comply with 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.

The personal data collected from the user in connection with the opt-out request will be used solely to fulfill the opt-out request.

Processing of your personal data for targeted advertising

For our purposes, "targeted advertising" means "displaying advertisements where the advertising is selected based on personal data obtained from your activities over time and across unaffiliated websites or online applications to predict your preferences or interests," as defined by the VCDPA.

For more details on how we process your personal data for targeted advertising purposes, you can refer to the section titled "Detailed Information on Personal Data Processing" within this document.

Your right to opt-out of the processing of your personal data for targeted advertising purposes and how to exercise it

You have the right to opt-out of the processing of your personal data for targeted advertising. This means that if you ask us to stop processing your data for targeted advertising, we will comply with 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 will use the personal data collected from the user in connection with the opt-out request solely to fulfill the opt-out request.

User's privacy rights under the Virginia Consumer Data Protection Act (VCDPA) and how to exercise them

The user can exercise certain rights regarding their 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 confirmation that 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 the correction of any inaccurate personal data we hold about you, taking into account the nature of the personal data and the purposes of processing the personal data.

Request the deletion of your personal data. You have the right to request the deletion of your personal data.
Obtain a copy of your personal data. We will provide you with your personal data in a portable and usable format that allows you to easily transfer it to another entity, provided that this is technically feasible.

Do not consent to the processing of your personal data for targeted advertising, the sale of personal data, or profiling to support decisions that produce legal effects 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 deny you, among other things, goods or services, charge you a different price, or provide you with a different level or quality of goods or services just because you have exercised your consumer privacy rights. However, if you refuse to provide us with your personal data or ask us to delete or stop selling your personal data, and such data or sale is necessary to provide you with goods or services, we may not be able to complete the transaction. To the extent permitted by law, we may offer you a different price, rate, level, quality, or selection of goods or services, including offering goods or services for free, if you have exercised your right to opt-out or if our offer is related to your voluntary participation in a loyalty, rewards, premium features, discounts, or club card program in good faith.

How to exercise your rights

To exercise the above-mentioned rights, you must submit your request by contacting us using the contact details provided in this document.
To respond to your request, we need to know who you are.
We will not respond to any requests if we cannot reasonably verify your identity and confirm that the personal data we hold relates to you. In such cases, we may ask you to provide additional information reasonably necessary to authenticate your identity and your request.
A consumer's request does not require the creation of an account with us. However, we may require you to use your existing account. We will use the personal data collected from the user in connection with their request solely for the purposes of authentication and will not further disclose, retain, or use 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 required to handle your request

We will respond to your request without undue delay, but in any case, no later than 45 days from the receipt of your request. If we need more time, we will explain the reasons and the necessary time. Please note that we may take up to 90 days to fulfill your request.
In case of refusal of the request, we will explain the reasons for the refusal without undue delay, but in any case, no later than 45 days from the receipt of the request. You have the right to appeal this decision by submitting a request to us using the details provided in this document. Within 60 days of receiving 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 rejected, you can turn to the Attorney General to file a complaint.

Responding to the request is free, for a maximum of two requests per year. If the request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to comply with the request. In either case, we will communicate our choices and explain the reasons.

Information for Users residing in Brazil

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this website and, if applicable, its parent company and its subsidiaries and affiliates (collectively referred to as "we," "our," or "us").
The provisions contained in this section apply to all Users who are residents in Brazil, in accordance with the "Lei Geral de Proteção de Dados" (such Users are hereinafter simply referred to as "you" or "your"). For such Users, these provisions supersede any other divergent or conflicting provisions contained in this privacy policy.

In this part of the document, the term "personal information" is used as defined by the "Lei Geral de Proteção de Dados" (LGPD).

Legal bases for processing your personal information

We process your personal information only if one of the legal bases for such processing exists. The legal bases are as follows:

Your consent to the processing activities in question;
Compliance with legal obligations that we are required to fulfill;
The performance of rules dictated by laws or regulations or by contracts, agreements, or other similar legal instruments;
Research studies conducted by research entities, preferably conducted on anonymized personal information;
Performance of a contract and the related pre-contractual obligations, if you are a party to such a contract;
Exercising our rights in court, in administrative procedures, or in arbitrations;
Defense or physical integrity of you or a third party;
Protection of health - within the context of procedures carried out by healthcare entities or professionals;
Our legitimate interest, provided that your fundamental rights and freedoms do not prevail over such interests; and
Credit protection.

To learn 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 know which categories of personal information are processed, you can refer to the section "Detailed Information on Personal Data Processing" in this document.

Why we process your personal information

To know why we process your personal information, please refer to the sections "Detailed Information on Personal Data Processing" and "Purposes of Collected Data Processing" in this document.

Your privacy rights in Brazil, how to submit a request, and how we will handle it

Your privacy rights in Brazil

You have the right to:

Obtain confirmation of the existence of processing activities concerning your personal information; Access your personal information;
Obtain rectification of your incomplete, inaccurate, or outdated personal information; Obtain anonymization, blocking, or deletion of unnecessary or excessive personal information, or of information that is processed in violation of the provisions of the LGPD; Obtain information about the possibility of providing or refusing your consent and the related consequences;

Obtain information about the third parties with whom we share your personal information; Obtain, upon your explicit request, the portability of your personal information (excluding anonymized information) to other product or service providers, provided that our trade secrets are safeguarded;

Obtain the deletion of personal information processed if the processing was based on your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply;
Revoke your consent at any time;

Submit a complaint regarding your personal information to the ANPD (National Data Protection Authority) or to a consumer protection entity;
Object to processing activities when such processing is not carried out in accordance with legal provisions;

Request clear and adequate information about the criteria and procedures used in automated decision-making processes; and
Request the review of decisions that affect your interests, made solely on the basis of automated decision-making processes concerning your personal information. These include decisions to define your personal, professional, consumer, or creditor profile, or other aspects of your personality.

You will never be discriminated against or otherwise suffer any treatment that is unfavorable to you as a result of exercising your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge at any time by using the contact details provided in this document or through your legal representative.

How and within what time we will handle your request

We will make every effort to respond to your request as soon as possible.
In any case, if we are unable to do so, we will ensure to communicate to you the factual or legal reasons that prevent us from immediately satisfying or complying with your request. If your personal information is not processed by us and we are able to do so, we will inform you of the individual or legal entity to whom you can address your requests.

If you decide to submit a request for access or a request to confirm the existence of the processing of personal information, please indicate whether you prefer to receive your personal information in electronic or paper format.
You should also let us know if you want an immediate response, in which case you will receive a simplified response, or if you need a complete response.

In the latter case, we will respond within 15 days from the date of your request, providing you with all the information concerning the origin of your personal information, the confirmation or non-confirmation of the existence of personal information concerning you, all the criteria used for the processing, and the purposes of such processing, while safeguarding our trade secrets and industrial secrets.

If you decide to submit a request for rectification, deletion, anonymization, or blocking of personal information, we will immediately inform the other parties with whom we have shared your personal information so that they can also comply with your request, except where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

When the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as provided for in the instruments made available by international law;
When the transfer is necessary to defend your life or physical integrity or that of third parties; when the transfer is authorized by the ANPD;

When the transfer results from an obligation assumed in the context of an international cooperation agreement;
When the transfer is necessary for the exercise of public order or for the performance of a public service;

When the transfer is necessary for compliance with a legal obligation, the performance of a contract and the related pre-contractual obligations, or the normal exercise of rights in court, administrative or arbitral proceedings.

Definitions and legal references

Personal Data (or Data)

Any information that directly or indirectly, alone or in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

Information collected automatically through this Website (including from third-party applications integrated into this Website), which can include: the IP addresses or domain names of the computers used by the User connecting with this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the visitor, the various time details per visit (e.g., the time spent on each page within the Website), and the details about the path followed within the Website 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 Data Supervisor)

The natural person, legal person, public administration, or any other body, association, or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person or legal entity, public authority, service, or other body which, individually or together with others, determines the purposes and means of the processing of Personal Data and the instruments adopted, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be understood as extending to all current member states of the European Union and the European Economic Area.

Cookie

Cookies are Tracking Tools consisting of small pieces of data stored in the User's browser.

Tracking Tool

Any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that enables the tracking of Users, for example by collecting or saving information through the User’s device.

Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement applies exclusively to this Website. Last update: March 30, 2023