Privacy and Cookie Policy

Hypn Vault Privacy and Cookie Policy

This Website collects some Personal Data from its Users.

Data Controller

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

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

Owner's email address: hypnrecords@pec.it Types of data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: email; first name; Cookies; Usage data; Data communicated while using the service; telephone number; surname; date of birth; address; username; password; geographic location; nation; city; billing address; shipping address; payment information; device information; answers to questions; click; keypress events; motion sensor events; mouse movements; position relative to scroll; 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 (Google Advertiser ID or IDFA identifier, for example); sex; VAT number; business name; profession; profile picture; screen; Place of work; POSTAL CODE; state; User ID; Data communicated in order to use the Service; Universally Unique Identifier (UUID).

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

Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website 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 consequence on the availability of the Service or on its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner. Any 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 additional 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 he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

Method and place of processing of collected data Method of treatment

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

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some legal systems, the Data Controller may be authorized to process Personal Data without the User's consent

another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;

the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
the treatment is necessary for the execution of a task of public interest or for the exercise of public powers with which the Data Controller is invested;
the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

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 more information, contact the Owner.
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 on the place of processing, the User can refer to the section relating to the 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 for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.

Storage period

The Data are processed and stored for the time required by the purposes for which they were collected. Therefore:

Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the treatment is based on the User's consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the processing of the collected data

The User's Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any malicious activity or fraudulent, 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, Management of productivity-related activities, Viewing content from external platforms , Tag management, Content and functionality performance testing (A/B testing), Platform services and hosting, SPAM protection, Advertising, Remarketing and behavioral targeting, Location-based interactions, Management of data collection and online surveys and Marketing.

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

Details on the processing of Personal Data

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

Contact the user

Mailing list or newsletter (this Website)

By registering with the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Website may be sent. User's email address could also be added to this list as a result of registering on this Website or after making a purchase.

Personal Data processed: email; first name.
Category of personal information collected pursuant to the CCPA: Identifiers. This type of treatment constitutes:

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

Contact form (this Website)

By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the header of the form.

Personal Data processed: surname; e-mail; first name.
Category of personal information collected pursuant to the CCPA: Identifiers. This type of treatment constitutes:

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

Contact by telephone (this Website)

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

Personal Data processed: telephone number.
Category of personal information collected pursuant to the CCPA: Identifiers. This type of treatment constitutes:

a sale pursuant to the CCPA and VCDPA

Payment management

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

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

paypal (paypal)

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

Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: Consult the Paypal privacy policy - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

PayPal Carrier Payments (Paypal)

PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows the User to make online payments using his mobile phone operator.

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

Place of processing: Consult the Paypal privacy policy - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; information on 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. Place of processing: Consult the Paypal privacy policy - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.

Amazon Payments (Amazon)

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

Personal Data processed: surname; purchase history; Usage data; e-mail; billing address; shipping address; payment information; first name; telephone number; password; Tracking Tools; username; various types of Data as specified in the privacy policy of the service.

Place of processing: Consult Amazon's privacy policy - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; commercial information;

information on the Internet.
This type of treatment constitutes:

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

Apple Pay (Apple Inc.)

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

Personal Data processed: surname; purchase history; Usage Data; e-mail; billing address; shipping address; payment information; first name; telephone number; Tracking Tools; 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 pursuant to the CCPA: Identifiers; commercial information;

information on the Internet.
This type of treatment constitutes:

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

Google Pay

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

Personal Data processed: surname; purchase history; Usage data; e-mail; billing address; shipping address; payment information; first name; telephone number; Tracking Tools; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; commercial information;

information on the Internet.
This type of treatment constitutes:

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

Tag management

This type of service is functional for the centralized management of the tags or scripts used on this Website. The use of these services involves the flow of User Data through them and, where appropriate, 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.
Place of processing: Ireland – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.

Management of data collection and online surveys

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

These services can be integrated with a wide range of third-party services to allow the Owner to perform subsequent actions with the Data processed - for example, contact management, sending messages, statistics, advertising and payment processing.

Advertisements for Meta leads

Advertisements for lead acquisition by Meta is an advertising and data collection service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the processing of Data, which allows advertising to be shown to Users in the form of forms already pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be asked to provide additional information.

Submitting the form involves the collection and processing of these Data by the Data Controller in accordance with this privacy policy and only for the specific purpose indicated in the form and/or within this privacy policy, where provided.

The User can exercise his rights at any time, including the right to withdraw consent to the processing of his Data, as specified in the section containing information on the User's rights in this privacy policy.

Personal Data processed: CAP; city; surname; date of birth; Data communicated while using the service; Usage data; e-mail; physical address; nation; first name; telephone number; profession; business name; sex; state; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt out ; Ireland - Privacy Policy - Opt out . Category of personal information collected pursuant to the CCPA: Identifiers; commercial information;

information on the Internet; information relating to the employment relationship. This type of treatment constitutes:

a sale pursuant to the CCPA and VCDPA

a share under the CCPA
targeted advertising according to the VCDPA

Management of activities related to productivity

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

Gmail (Google Ireland Limited)

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

Personal Data processed: city; surname; Cookies; date of birth; e-mail; address; nation; first name; telephone number; password; geographic location; username.

Place of processing: Ireland – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet; data of

geolocation.

Google Docs

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

Personal Data processed: city; surname; date of birth; Data communicated while using the service; Usage data; e-mail; profile picture; physical address; device information; first name; telephone number; VAT number; geographic location; profession; business name; screen; Place of work; sex; Tracking Tools; username.

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

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet; geolocation data; sensor-based information; information relating to the employment relationship.

This type of treatment constitutes:

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

Google Sheets (Google LLC)

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

Personal Data processed: city; surname; date of birth; Data communicated while using the service; Usage Data; e-mail; physical address; device information; nation; first name; telephone number; VAT number; geographic location; business name; Tracking Tools; username.

Place of processing: United States - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; commercial information;

information on the Internet; geolocation data. This type of treatment constitutes:

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

Hosting and backend infrastructure

This type of service has the function of hosting Data and files that allow this Website to function, allow its distribution and provide a ready-to-use infrastructure to deliver specific functions of this Website.

Some of the services listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

iubenda Consent Solution (iubenda srl)

The Consent Solution offered by iubenda allows you to keep and consult the registers relating to the consent and preferences expressed by End Users regarding the processing of their Personal Data.

Personal Data processed: Data communicated while using the service; Tracking Tool. Place of processing: Italy – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.

Google Cloud Storage

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

Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy ; United States - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers.
This type of treatment constitutes:

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

Interaction with social networks and external platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User's privacy settings relating to each social network.

This type of service could still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out of 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: Cookies; Usage data.
Place of processing: Consult the Paypal privacy policy - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.

This type of treatment constitutes:
a sale pursuant to the CCPA and VCDPA

Location-based interactions

Geolocation (this Website)

This Website may collect, use and share Data relating to the User's geographical location, in order to provide location-based services.
Most browsers and devices provide tools to deny geographic tracking by default. If the User has expressly authorized this possibility, this Website may receive information on its actual geographical position.

Personal Data processed: approximate location; geographic location.
Category of personal information collected pursuant to the CCPA: Geolocation data. This type of treatment constitutes:

a sale under the CCPA and VCDPA a share under the CCPA
targeted advertising according to the 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 the CCPA and VCDPA a share under the CCPA
targeted advertising according to the 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 the CCPA and VCDPA a share under the CCPA
targeted advertising according to the 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 treatment constitutes:

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

Smiley - 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 the CCPA and VCDPA a share under the CCPA
targeted advertising according to the VCDPA

SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the processing of Data.
The use of the reCAPTCHA system is subject to the privacy policy and terms of use of Google.

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

Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information; information

indirect.
This type of treatment constitutes:

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

Advertising

This type of service allows the User's Data to be used for commercial communication purposes. These communications are shown on this Website in the form of banners and other forms of advertising, also in relation to the interests of the User.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.

Some of the services listed below may use Tracking Tools to identify Users or they may use the behavioral retargeting technique, i.e. displaying personalized advertisements based on the User's interests and behaviour, including those detected outside this Website. For more information on this, we suggest you check the privacy policies of the respective services. Generally, services of this type offer the possibility of deactivating this tracking. In addition to any opt-out functions provided by any of the services listed in this document, the User can read more about how to opt out of interest-based advertising in the appropriate section "How to opt out of interest-based advertising" in this document. document.

Czech Publisher Exchange (Czech Publisher Exchange zspo)

Czech Publisher Exchange is an advertising service provided by Czech Publisher Exchange zspo Personal Data processed: Usage data; Tracking Tools.
Place of processing: Czech Republic – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.

This type of treatment constitutes:

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

Google Ads similar audiences

Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing, which uses Google Ads Remarketing Data to show advertisements to Users with 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 want to be included in Similar Audiences can opt-out and disable the use of Ad Trackers by visiting Google's Ad Settings .

For an understanding of Google's use of Data, please see our partner policies

by Google .
Personal Data processed: Usage data; Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out . Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

Meta Audience Network

Meta Audience Network is an advertising service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the processing of the Data. For an understanding of Meta's use of data, please consult Meta's data policy .

To allow the Meta Audience Network to function, this Website may use certain identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for OS) or technologies similar to cookies. Among the ways in which Audience Network proposes advertising messages to the User, there is also the use of the latter's advertising preferences. The User can control the sharing of his advertising preferences within the Facebook Ad settings .

You can opt-out of some Audience Network targeting features through your device settings. For example, you can change the advertising settings available for mobile devices, or follow the instructions applicable to Audience Network that may be present in this privacy policy.

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

Place of processing: United States – Privacy Policy – Opt out ; Ireland - Privacy Policy - Opt out . Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

Meta Lookalike Audience

Meta Lookalike Audience is an advertising and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Data Controller manages the processing of the Data, which uses the Data collected through the Meta Similar Audience service Meta in order to show advertisements to Users with behavior 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's applications and services.

Based on this Data, personalized ads will be shown to Users suggested by Meta's Lookalike Audience.

Users can opt out of using Meta Trackers for ad personalization by visiting this opt-out page .

Personal Data processed: Usage data; Tracking Tools.
Place of processing: United States – Privacy Policy – Opt out ; Ireland - Privacy Policy - Opt out . Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

Registration and authentication

By registering or authenticating, the User allows this Website to identify him and give him access to dedicated services.
Depending on what is indicated below, the registration and authentication services could be provided with the help of third parties. If this happens, this Website will be able to 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; to learn more, please refer to the description of each service.

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. Place of processing: Consult the Paypal privacy policy - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information.
This type of treatment constitutes:

a sale pursuant to the CCPA and VCDPA

Remarketing and behavioral targeting

This type of service allows this Website and its partners to communicate, optimize and serve advertisements based on past use of this Website by the User.
This activity is facilitated by the tracking of Usage Data and by the use of Tracking Tools to collect information which is then transferred to the partners who manage the remarketing and behavioral targeting activities.

Some services offer a remarketing option based on email address lists.
Generally, services of this type offer the possibility of deactivating this tracking. In addition to any opt-out functions provided by any of the services listed in this document, the User can read more about how to opt out of interest-based advertising in the appropriate section "How to opt out of interest-based advertising" in this document. document.

Facebook Remarketing

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

Personal Data processed: Usage data; Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out . Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

Google Ads Remarketing

Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing, which 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 review Google's partner policies .

Users can choose not to use Google Trackers for ad personalization by visiting Google's Ad Settings .

Personal Data processed: Usage data; Tracking Tools.
Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

Meta Custom Audience

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

Users can opt out of using Meta Trackers for ad personalization by visiting this opt-out page .

Personal Data processed: email; Tracking Tools.
Place of processing: United States – Privacy Policy – Opt out ; Ireland - Privacy Policy - Opt out . Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

TikTok Remarketing ( TikTok Information Technologies UK Limited )

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

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

Place of processing: United Kingdom – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

Platform services and hosting

These services are intended to host and operate key components of this Website, making it possible to deliver this Website from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for electronic commerce, for processing payments, etc. The use of these tools involves the collection and processing of Personal Data.

Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

Shopify

Shopify is a platform provided by Shopify Inc. which allows the Owner to develop, operate and host a website dedicated to electronic commerce.

Personal Data processed: surname; Usage Data; e-mail; billing address; shipping address; payment information; device information; first name; telephone number; Tracking Tools.

Place of processing: Canada – Privacy Policy ; Ireland - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet.

This type of treatment constitutes:

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

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour.

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Cookies; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out .
Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

a sale pursuant to the CCPA and VCDPA

Google Analytics with anonymized IP (Google Ireland Limited)

This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened within the United States.

a sale pursuant to the CCPA and VCDPA

Google Ads conversion tracking

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

Personal Data processed: Usage data; Tracking Tools.
Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

Google Analytics 4

Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of data, ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.

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

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

Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out .
Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet; data of

geolocation.
This type of treatment constitutes:

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

Advertising Reporting Features in Google Analytics

Google Analytics on this Website has Advertising Reporting Features enabled, which collect additional information from the DoubleClick cookie (web activity) and device advertising IDs (application activity). This allows the Owner to analyze specific Data relating to Users' behaviors and interests (Traffic data and User interaction data with ads) and, if enabled, Demographic Data (information on age and gender).

Users can choose not to use Google cookies by visiting Google's [Ad settings] (https://adssettings.google.com/authenticated).

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

Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out . Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

Google Analytics demographics and interests reports

Google Analytics Demographics and Interests Reporting is an advertising reporting feature that makes Demographics and Interests Data available within Google Analytics for this Website (Demographics means Age and Gender Data ).

Users can choose not to use Google cookies by visiting Google's [Ad settings] (https://adssettings.google.com/authenticated).

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

Place of processing: United States – Privacy Policy – Opt Out ; Ireland - Privacy Policy - Opt Out . Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

Meta ads conversion tracking (Meta pixel)

Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Data Controller manages data processing, which connects data from the Meta ads with actions performed within this Website. The Meta pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

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

Meta Event Manager

Meta Events Manager is a statistics service provided by Meta Platforms Ireland Limited or by Meta Platforms, Inc., depending on how the Owner manages the processing of Data. By integrating the Meta pixel, Meta Events Manager can give the Owner information on the traffic and interactions on this Website.

Personal Data processed: Usage data; Tracking Tools.
Place of processing: Ireland – Privacy Policy – Opt out ; United States - Privacy Policy - Opt out . Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

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

TikTok (TikTok Inc.) Conversion Tracking

TikTok Conversion Tracking is an analytics service provided by TikTok Inc. that links data from the TikTok ad network with actions performed on this Website. The TikTok pixel tracks conversions that can be attributed to TikTok ads and allows you to target groups of Users based on their previous use of this Website.

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

Place of processing: United States - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

YouTube Analytics and Reporting APIs

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

Through this Service, this Website may collect Data directly or indirectly on or from the User's devices, including through the use of Tracking Tools. Users can limit this access to their Data through the security settings page provided by Google. The
Users, at any time, can contact the Owner to request further information on privacy settings through the contact details provided in this document.

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

Personal Data processed: Data communicated while using the service; Data communicated in order to use the Service; Usage data; User ID; device information; Tracking Tools.

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

Content and functionality performance testing (A/B testing)

The services contained in this section allow the Data Controller to track and analyze the response from the User, in terms of traffic or behaviour, in relation to changes to the structure, text or any other component of this Website .

Google Optimize (Google Ireland Limited)

Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").

Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Cookies; Usage data.
Place of processing: Ireland – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

a sale under the VCDPA

Google Optimize 360 (Google Ireland Limited)

Google Optimize 360 is an A/B testing service provided by Google Ireland Limited ("Google").

This service allows the Owner to target groups of Users based on their past use of this Website. Users who disable tracking by Google Analytics will not be included in the experiments created within Google Optimize 360.

Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

a sale pursuant to the CCPA and VCDPA

Viewing 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 to interact with them.
This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style visualization service managed by Google Ireland Limited that allows this Website to integrate such content within its pages.

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

Place of processing: Ireland – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

a sale under the VCDPA

SoundCloud Widgets (SoundCloud Limited)

Soundcloud is an audio content delivery service managed by SoundCloud Limited that allows this Website to integrate such content within its pages.

Personal Data processed: Usage data.
Place of processing: Germany – Privacy Policy .
Category of personal information collected pursuant to the CCPA: Internet information. This type of treatment constitutes:

a sale pursuant to the CCPA and VCDPA

YouTube Data API

YouTube Data API is a video content visualization service managed by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages data processing, which allows this Website to integrate functions normally executable on YouTube so that users Users can watch, search and manage YouTube content directly within this Website.

Personal Data processed: Data communicated while using the service; Data communicated in order to use the Service; Usage data; User ID; device information; Tracking Tools.

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

YouTube video widgets

This type of treatment constitutes:

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

YouTube Video Widget (Enhanced Privacy Mode)

YouTube is a video content viewing service managed by Google LLC or by Google Ireland Limited, depending on how the Owner manages data processing, which allows this Website to integrate such content within its pages.
This widget is set up so that YouTube does not save information and cookies about Users on this Website, unless they play the video.

Personal Data processed: Usage data; Universally Unique Identifier (UUID); Tracking Tools. Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .
Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet. This type of treatment constitutes:

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

Learn how to opt out of interest-based advertising

In addition to any opt-out function provided by any of the services listed in this document, Users can read more about how to disable interest-based advertising in the appropriate section of the Cookie Policy.

Further information on the processing of Personal Data iubenda Cookie Solution (Cookie for remote consent)

The iubenda Remote Consent Cookie (_iub_cs-X) is installed by the iubenda Cookie Solution and stores the User's preferences relating to Tracking Tools in the .iubenda.com domain.

Cookie Solution by iubenda (Cookie for consent)

The iubenda Consent Cookie (_iub_cs-X) is installed by the iubenda Cookie Solution and stores the User's preferences relating to Tracking Tools in the local domain.

User rights

Users can exercise certain rights with reference to the Data processed by the Owner. In particular, the User has the right to:

withdraw consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data.
oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.

access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.

obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.

receive their data or have them transferred to another owner. The User has the right to receive his Data in a structured format, commonly used and readable by an automatic device and, where technically

feasible, to obtain the unhindered transfer to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it. propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

Cookie Policy

This Website uses Trackers. To find out more, the User can consult the Cookie Policy .

Further information on treatment Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuses in the use of this Website or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, 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 and maintenance logs

For needs related to operation and maintenance, this Website and any third party services used by it may collect system logs, i.e. files that record the interactions and which 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 third-party services used support them, the User is invited to consult 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 notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users via one of the contact information you have. Therefore, please consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Information for California Consumers

This part of the document complements and completes the information contained in the rest of the privacy policy and is provided by the company that operates this website and, where applicable, by its parent company, its subsidiaries and its affiliates (for the 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 simply "you", "your", "your"), who are consumers residing in the state of California, United States of America, to pursuant 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 differing or conflicting provisions contained in the privacy policy.

We use the terms "personal information" (and "sensitive personal information") as defined in the California Consumer Privacy Act (CCPA) in this part of the document.

Notice at the time of collection

Categories of personal information collected, used, sold or shared

In this section, we summarize the categories of personal information that we have collected, used, sold or shared and their purposes. You can read about these activities in detail in the section entitled "Detailed information on the processing of personal data" within this document.

Information We Collect: The categories of personal data we collect

We have collected the following categories of personal information about you: identifiers, business information, internet information, geolocation data, sensory information, occupational information, and inferred information.

We have collected the following categories of sensitive personal data: username, password, payment information, username, password, payment information, username, VAT number, payment information, username and VAT number.

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

Your right to restrict 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 data to only what is necessary for the performance of the services or the supply of the goods, as reasonably expected by an average consumer.

We may also use your sensitive personal data to fulfill specific purposes required by law (such as, but not limited to, help ensure security and integrity; undertake 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, the user has the right to freely request, at any time, that his sensitive personal data are not used or disclosed. This means that whenever you ask us to stop using your sensitive personal data, we will comply with your request and instruct our service providers and contractors to do the same.

To fully exercise your right to restrict the use or disclosure of your sensitive personal data, you may 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 connection with the submission of the request is used only to fulfill the request itself.

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

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

We may use your personal data to enable the website and its features to operate ("business purposes").

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

We may also use your personal data for other reasons, for example for commercial purposes (as indicated in the "Detailed information on the processing of personal data" section herein), as well as to comply with the law and defend our rights before to the competent authorities if our rights and interests are threatened or 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 keep your personal information?

Unless otherwise specified within the "Detailed information on the processing of personal data" section, we will not retain your personal information longer than is reasonably necessary for the purpose or purposes for which it was collected.

How we collect information: What are the sources of the personal information we collect?

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

For example, the user directly provides their personal data when sending requests through the forms on the Site. Personal data is also provided indirectly when browsing this website, as personal information is observed and collected automatically.

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

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

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

We disclose your personal data with the third parties detailed in the section entitled "Detailed information on the processing of personal data" in this document. These third parties are grouped and categorized according to the different purposes of the processing.

Selling or sharing your personal data

For our purposes, the term "sale" means any "sale, lease, release, disclosure, dissemination, making available, transfer, or other oral, written, or electronic communication of a consumer's personal information by the Company to a third party , for monetary or other consideration," as defined by the CCPA.

This means that, for example, a sale can occur every time an application manages advertisements, or carries out statistical analysis on traffic or views, or simply because it uses tools such as plugins for social networks and the like.

For our purposes, "sharing" means any "sharing, renting, releasing, disclosing, disseminating, making available, transferring, or other oral, written, electronic, or other communication of a consumer's personal information by the Company to a third party for cross-context behavioral advertising, whether or not for monetary or other consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which there is no exchange of money", as defined by the CCPA.

Please note that exchanging personal information with a service provider under a written agreement that meets the requirements set forth 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 to exercise it

We sell or share your personal data with the third parties detailed in the section entitled "Detailed information on the processing of personal data" in 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 information, we will comply with your request.

Such requests may be made freely, at any time, without making any verifiable requests.
To fully exercise your opt-out right, 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 global privacy control that you enable, such as the Global Privacy Control ("GPC"), you are welcome to do so and we will comply with your request. GPC is a setting or extension on your browser or mobile device and acts as a mechanism that websites can use to indicate that they support the GPC signal. If you want to use the GPC, you can download and activate it through a browser or a suitable browser extension. Learn more about downloading GPC here.

Personal information collected from you in connection with submitting your opt-out request is only used to fulfill your opt-out request.

Once you have opted out, 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 your personal information to enable the operation of this website and its features ("business purposes"). In these cases, your personal information will be treated as necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of the compatible operational purposes.

We may also use your personal data for other reasons, for example for commercial purposes (as indicated in the "Detailed information on the processing of personal data" section herein), as well as to comply with the law and defend our rights before to the competent authorities if our rights and interests are threatened or 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 keep your personal information?

Unless otherwise specified within the "Detailed information on the processing of personal data" section, we will not retain your personal information longer than is reasonably necessary for the purpose or purposes for which it was collected.

Your privacy rights under California Consumer Privacy Law and how to exercise them

Right of access to personal information: right to know and portability

You have the right to request that we disclose:

the categories of personal information 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 this information;

the specific personal information we have collected about you.

You also have the right to know what personal information is being sold or shared and with whom. In particular, the user has the right to request two separate lists from us in which they are disclosed

the categories of personal information we have sold or shared about you and the categories of third parties to whom the personal information has been sold or shared;
the categories of personal information we disclosed about you for a business purpose and the categories of people to whom it was disclosed for a business purpose.

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

In the event that the response is provided electronically, the attached information will be "transportable", i.e. provided in a format that can be easily used to allow the user to transmit the information to another entity without hindrance, provided that this is technically doable.

Right to request the deletion of your personal data

You have the right to request the deletion of your personal information, subject to the exceptions provided by law (for example, but not limited to, in the event that the information is used to identify and repair errors on the website, to detect security incidents and protect against fraudulent or illegal activity, to exercise certain rights, etc.)

If no statutory exception applies, following your exercise of your right, we will delete your personal information and notify all of our service providers and any third parties to whom we have sold or shared your personal information to do so - provided that this is technically feasible and does not involve a disproportionate effort.

Right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we hold 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 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 we restrict the use or disclosure of your sensitive personal information.

Right not to suffer retaliation 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 discriminate against you, including, but not limited to, by denying you goods or services, charging you a different price or providing 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 you ask us to delete or stop selling your Personal Data, and that Personal Data or the 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 make a verifiable request by contacting us using the details provided in this document.

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

provide sufficient information to enable us to reasonably verify that you are the individual about whom we have collected the personal information or an authorized representative;
describe your request in sufficient detail to enable us to understand, evaluate and respond to it appropriately.

We will not respond to any request if we are unable to verify your identity and therefore confirm that the personal information we hold actually relates to you.

To make a verifiable consumer inquiry you do not need to create an account with us. Personal information collected from you in connection with verifying your request will be used for verification purposes only and will not be disclosed further, retained longer than necessary for verification purposes, or used for any unrelated purpose.

If you cannot make a verifiable request yourself, you may 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 claim on behalf of a minor under your parental authority. It is possible to submit a maximum number of 2 requests within 12 months.

How and when we will have to handle your request

We will acknowledge receipt of your verifiable request within 10 days and provide information on how to process your request.

We will respond to your request within 45 days of receiving it. Should we need more time, we will explain the reasons and the necessary time. In this regard, please note that it may take up to 90 days to respond to your request.

Our disclosures will cover the prior 12-month period. Only with respect to personal data collected on or after 1 January 2022, you have the right to request disclosure beyond the 12-month period and we will provide it to you, unless this proves impossible or requires effort. disproportionate.

In the event that the request is rejected, we will explain the reasons for the refusal.

We will not charge you for processing or responding to your verifiable request, unless such request is manifestly unfounded or excessive. In these cases, we may charge a reasonable fee or refuse to act on your request. In both cases, we will communicate our choice and explain the reasons.

Information for Virginia Consumers

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the data controller who manages this Application and, where appropriate, by its parent company, its subsidiaries and its affiliates (for the 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 simply "you", "your", "your"), who are consumers residing in the Commonwealth of Virginia, pursuant to the "Virginia Consumer Data Protection Act" (the "VCDPA") and, for such consumers, these provisions supersede any other possibly differing or conflicting provisions contained in the privacy policy.

The terms "personal data" (and "sensitive data") as defined in the VCDPA are used in this part of the document.

Categories of personal data processed

In this section we summarize the categories of personal data we have processed and their purposes. You can read about these activities in detail in the section entitled "Detailed information on the processing of personal data" within this document.

Categories of personal data collected

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

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

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

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

Why we process your personal data

To find out why we process your personal data, you can read the sections entitled "Detailed information on the processing of personal data" and "The purposes of the processing" within this document.

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

How we use the data we collect: sharing your personal data with third parties

We share your personal data with the third parties detailed in the section entitled "Detailed information on the processing of personal data" in this document. These third parties are grouped and categorized according to the different purposes of the processing.
For our purposes, "third party" means "a natural or legal person, public authority, agency or body other than the consumer, the controller, the processor or an affiliate of the processor controller or processor", as defined by the AVCP.

Sale of your personal data

For our purposes, the term "sale" means any "exchange of personal data for 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 processor does not constitute a sale.

As detailed in the "Detailed Information on Privacy Policy" section of this document, our use of your personal information may be considered a sale under the VCDPA.

Your right to opt out of the sale of your personal data and how to exercise this 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 of withdrawal, you can contact us at any time using the contact details provided in this document.

The personal data collected from you in connection with submitting your opt-out request is only used to fulfill your request.

Processing of your personal data for targeted advertising

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

For more details on the processing of your personal data for targeted advertising purposes, you can read the section entitled "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 purposes and how to exercise it

You have the right to object to 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 opt-out right you can contact us at any time, using the contact details provided in this document.

We will use the personal data collected from you in connection with sending your opt-out request only to fulfill your opt-out request.

Your privacy rights under the Virginia Consumer Data Protection Act and how you can exercise them

You can exercise certain rights relating to 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 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 the processing of 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 this is technically feasible.

not allow the processing of your personal data for the purpose of targeted advertising, the sale of personal data or profiling in support of decisions that produce legal or similar effects on you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not deny you, inter alia, goods or services, we will not charge you a different price,

or provide 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 you ask us to delete or stop selling your Personal Data, and that Personal Data or the 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 free of charge, if you have exercised the right of withdrawal or if our offer is related to your voluntary participation in a loyalty programme, rewards, premium features, discounts or bona fide club cards.

How to exercise your rights

To exercise the rights described above, the user must submit his request by contacting us using the contact details provided in this document.

In order to be able to respond to your request, we need to know who you are.

We will not respond to any request unless we are able to verify your identity with commercially reasonable efforts and thus confirm that the personal data we hold does indeed relate to you. In these cases, we may ask you to provide additional information reasonably necessary to authenticate you and your request.

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 the personal data collected from you in connection with your request for authentication purposes only, and will not further disclose the personal data, retain it longer than necessary for authentication purposes, or use it for any unrelated purpose.

If you are an adult, you can apply 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 and at the latest within 45 days of receipt. Should we need more time, we will explain the reasons and the necessary time. In this regard, please note that it may take up to 90 days to respond to your request.

In case of refusal of the request, we will explain the reasons for the refusal without unjustified delay, but in any case and at the latest within 45 days of receipt of the request. You have the right to appeal this decision by making a request to us using the details provided in this document. Within 60 days of receiving your appeal, we will notify you in writing of any actions we take or not take in response to your appeal, including a written explanation of the reasons for the decisions. If the appeal is rejected, the insured person can apply to the Attorney General to file a complaint.

There is no cost for responding to your request, up to a maximum of two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on your request. In both cases, we will communicate our choices and explain the reasons.

Information for Users residing in Brazil

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Website and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as " we", "our" or "our").
The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the "Lei Geral de Proteção de Dados" (such Users are referred to below simply as "you", "your", "you" or "your"). For these Users, these provisions prevail over any other possibly divergent or conflicting provision 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 under which we process your personal information

We only process your personal information if one of the legal grounds 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 comply with;
the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
studies conducted by research institutions, preferably carried out on anonymised personal information; the execution of a contract and the related pre-contractual obligations, if you are a party to such a contract;
the exercise of our rights in court, administrative proceedings or arbitration;
your defense or physical safety or that of a third party;
health protection - in the context of procedures implemented by entities or professionals in the health sector;
our legitimate interest, provided your fundamental rights and freedoms do not override those 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 which categories of personal information are processed, you can refer to the "Details on the processing of Personal Data" section in this document.

Why we treat your personal information

To find out why we process your personal information, please refer to the "Details on the processing of personal data" and "Purpose of processing the collected data" sections in this document.

Your privacy rights in Brazil, how to make a request and how it will be handled by us

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 the rectification of your incomplete, inaccurate or outdated personal information; obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is treated contrary to the provisions of the LGPD; obtain information regarding the possibility of giving 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 (with the exception of anonymised information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;

obtain the cancellation of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply;
withdraw your consent at any time;

lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;

request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And
request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you suffer any treatment that is unfavorable to you in any way, following the exercise of your rights.

How to submit a request

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

How and in what time we will handle your request

We will do our best to answer your request as soon as possible.
In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons which prevent us from immediately complying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the natural or legal person to whom to address your requests.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require complete disclosure.

In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the treatment and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization or blocking of personal information , we will make sure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn satisfy your request - except in cases 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 required by the tools made available by international law;
when the transfer is necessary to defend the life or limb of you or a third party; 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 the fulfillment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.

Definitions and legal references

Personal Data (or Data)

Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is information collected automatically through this Website (also by third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained 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 operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User

The individual who uses this Website who, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refer.

Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, according to what is set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures relating to the functioning and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool through which the Personal Data of Users are 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 is intended to extend to all current member states of the European Union and the European Economic Area.

Cookies are Tracking Tools that consist of small portions of data stored in the User's browser.

Tracking Tool

Tracker means any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allows tracking Users, for example by collecting or saving information on the User's device.

Legal references

This privacy statement has been prepared 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 modification: 30 March 2023