www.workdraftstudio.com
PRIVACY POLICY
www.workdraftstudio.com
Privacy
Policy of www.workdraftstudio.com
This Application collects some
Personal Data from its Users.
This document contains a
section dedicated to Californian consumers and their privacy rights.
This document contains a
section dedicated to Virginia consumers and their privacy rights.
This document contains a
section dedicated to Colorado consumers and their privacy rights.
This document contains a
section dedicated to Connecticut consumers and their privacy rights.
This document contains a
section dedicated to Utah consumers and their privacy rights.
This document contains a
section dedicated to Users in Switzerland and their privacy rights.
This document contains a
section dedicated to Brazilian Users and their privacy rights.
This document can be printed for
reference by using the print command in the settings of any browser.
Owner and
Data Controller
WorkDraft Studio Limited
346a Farnham Road, Slough, SL2 1BT, United Kingdom
Owner contact email: info@workdraftstudio.com
Types of
Data collected
Among the types of Personal Data
that this Application collects, by itself or through third parties, there are:
Usage Data; Trackers; various types of Data.
Complete details on each type of
Personal Data collected are provided in the dedicated sections of this privacy
policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory
and failure to provide this Data may make it impossible for this Application to
provide its services. In cases where this Application specifically states that
some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the
owners of third-party services used by this Application serves the purpose of
providing the Service required by the User, in addition to any other purposes
described in the present document and in the Cookie Policy.
Users are responsible for any
third-party Personal Data obtained, published or shared through this
Application.
Mode and
place of processing the Data
Methods of
processing
The Owner takes appropriate
security measures to prevent unauthorised access, disclosure, modification, or
unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools,
following organisational procedures and modes strictly related to the purposes
indicated. In addition to the Owner, in some cases, the Data may be accessible
to certain types of persons in charge, involved with the operation of this
Application (administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies) appointed,
if necessary, as Data Processors by the Owner. The updated list of these
parties may be requested from the Owner at any time.
Place
The Data is processed at the
Owner's operating offices and in any other places where the parties involved in
the processing are located.
Depending on the User's location, data transfers may involve transferring the
User's Data to a country other than their own. To find out more about the place
of processing of such transferred Data, Users can check the section containing
details about the processing of Personal Data.
Retention
time
Unless specified otherwise in
this document, Personal Data shall be processed and stored for as long as
required by the purpose they have been collected for and may be retained for
longer due to applicable legal obligation or based on the Users’ consent.
The
purposes of processing
The Data concerning the User is
collected to allow the Owner to provide its Service, comply with its legal
obligations, respond to enforcement requests, protect its rights and interests
(or those of its Users or third parties), detect any malicious or fraudulent
activity, as well as the following: Displaying content from external platforms,
Data transfer outside the EU, Data transfer outside of the UK and Analytics.
For specific information about
the Personal Data used for each purpose, the User may refer to the section
“Detailed information on the processing of Personal Data”.
Detailed
information on the processing of Personal Data
Personal Data is collected for
the following purposes and using the following services:
· Analytics
The
services contained in this section enable the Owner to monitor and analyse web
traffic and can be used to keep track of User behaviour.
Google
Analytics (Universal Analytics) with anonymised IP
Google
Analytics (Universal Analytics) is a web analysis service provided by Google
LLC or by Google Ireland Limited, depending on how the Owner manages the Data
processing, (“Google”). Google utilises the Data collected to track and examine
the use of this Application, to prepare reports on its activities and share
them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of
its own advertising network.
This integration of Google Analytics anonymises your IP address. It works by
shortening Users' IP addresses within member states of the European Union or in
other contracting states to the Agreement on the European Economic Area. Only
in exceptional cases will the complete IP address be sent to a Google server
and shortened within the US.
Personal
Data processed: Trackers; Usage Data.
Place of
processing: United States – Privacy
Policy – Opt Out; Ireland
– Privacy
Policy – Opt Out.
Category of
personal information collected according to CCPA: internet information.
This
processing constitutes:
o a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
· Displaying content from external platforms
This type
of service allows you to view content hosted on external platforms directly
from the pages of this Application and interact with them. Such services are
often referred to as widgets, which are small elements placed on a website or
app. They provide specific information or perform a particular function and
often allow for user interaction.
This type of service might still collect web traffic data for the pages where
the service is installed, even when Users do not use it.
Google
Fonts
Google
Fonts is a typeface visualisation service provided by Google LLC or by Google
Ireland Limited, depending on how the Owner manages the Data processing, that
allows this Application to incorporate content of this kind on its pages.
Personal
Data processed: Trackers; Usage Data.
Place of
processing: United States – Privacy
Policy; Ireland – Privacy
Policy.
Category of
personal information collected according to CCPA: internet information.
This
processing constitutes:
o a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
Cookie
Policy
This Application uses Trackers.
To learn more, Users may consult the Cookie
Policy.
Further
Information for Users
Legal basis
of processing
The Owner may process Personal
Data relating to Users if one of the following applies:
· Users have
given their consent for one or more specific purposes.
· provision
of Data is necessary for the performance of an agreement with the User and/or
for any pre-contractual obligations thereof;
· processing
is necessary for compliance with a legal obligation to which the Owner is
subject;
· processing
is related to a task that is carried out in the public interest or in the
exercise of official authority vested in the Owner;
· processing
is necessary for the purposes of the legitimate interests pursued by the Owner
or by a third party.
In any case, the Owner will
gladly help to clarify the specific legal basis that applies to the processing,
and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.
Further
information about retention time
Unless specified otherwise in
this document, Personal Data shall be processed and stored for as long as
required by the purpose they have been collected for and may be retained for
longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
· Personal
Data collected for purposes related to the performance of a contract between
the Owner and the User shall be retained until such contract has been fully
performed.
· Personal
Data collected for the purposes of the Owner’s legitimate interests shall be
retained as long as needed to fulfill such purposes. Users may find specific
information regarding the legitimate interests pursued by the Owner within the
relevant sections of this document or by contacting the Owner.
The Owner may be allowed to
retain Personal Data for a longer period whenever the User has given consent to
such processing, as long as such consent is not withdrawn. Furthermore, the
Owner may be obliged to retain Personal Data for a longer period whenever
required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore,
the right of access, the right to erasure, the right to rectification and the
right to data portability cannot be enforced after expiration of the retention
period.
The rights
of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain
rights regarding their Data processed by the Owner.
In particular, Users have the
right to do the following, to the extent permitted by law:
· Withdraw
their consent at any time. Users have the right to withdraw consent
where they have previously given their consent to the processing of their
Personal Data.
· Object to
processing of their Data. Users have the right to object to the
processing of their Data if the processing is carried out on a legal basis
other than consent.
· Access
their Data. Users have the right to learn if Data is being processed by the
Owner, obtain disclosure regarding certain aspects of the processing and obtain
a copy of the Data undergoing processing.
· Verify and
seek rectification. Users have the right to verify the accuracy of their Data and ask
for it to be updated or corrected.
· Restrict
the processing of their Data. Users have the right to
restrict the processing of their Data. In this case, the Owner will not process
their Data for any purpose other than storing it.
· Have their
Personal Data deleted or otherwise removed. Users have the right to
obtain the erasure of their Data from the Owner.
· Receive
their Data and have it transferred to another controller. Users
have the right to receive their Data in a structured, commonly used and machine
readable format and, if technically feasible, to have it transmitted to another
controller without any hindrance.
· Lodge a
complaint. Users have the right to bring a claim before their competent data
protection authority.
Users are also entitled to learn
about the legal basis for Data transfers abroad including to any international
organization governed by public international law or set up by two or more
countries, such as the UN, and about the security measures taken by the Owner
to safeguard their Data.
Details about the right to
object to processing
Where Personal Data is processed for a public
interest, in the exercise of an official authority vested in the Owner or for
the purposes of the legitimate interests pursued by the Owner, Users may object
to such processing by providing a ground related to their particular situation
to justify the objection.
Users must know that, however, should their
Personal Data be processed for direct marketing purposes, they can object to
that processing at any time, free of charge and without providing any
justification. Where the User objects to processing for direct marketing
purposes, the Personal Data will no longer be processed for such purposes. To
learn whether the Owner is processing Personal Data for direct marketing
purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User
rights can be directed to the Owner through the contact details provided in
this document. Such requests are free of charge and will be answered by the
Owner as early as possible and always within one month, providing Users with
the information required by law. Any rectification or erasure of Personal Data
or restriction of processing will be communicated by the Owner to each
recipient, if any, to whom the Personal Data has been disclosed unless this
proves impossible or involves disproportionate effort. At the Users’ request,
the Owner will inform them about those recipients.
Transfer of
Personal Data outside of the European Union
Data transfer abroad based on
standard contractual clauses
If this is the legal basis, the
transfer of Personal Data from the EU to third countries is carried out by the
Owner according to “standard contractual clauses” provided by the European
Commission.
This means that Data recipients have committed to process Personal Data in
compliance with the data protection standards set forth by EU data protection
legislation. For further information, Users are requested to contact the Owner
through the contact details provided in the present document.
Transfer of
Personal Data outside of the United Kingdom
Data transfer abroad based on
standard contractual clauses (UK)
If this is the legal basis, the
transfer of Personal Data from the UK to third countries is carried out by the
Owner according to “standard contractual clauses” provided by the European
Commission.
This means that Data recipients
have committed to process Personal Data in compliance with the data protection
standards set forth by EU data protection legislation, which are recognized as
valid also under UK law. For further information, Users are requested to
contact the Owner through the contact details provided in the present document.
Further
information for Users in Switzerland
This section applies to Users in
Switzerland, and, for such Users, supersedes any other possibly divergent or
conflicting information contained in the privacy policy.
Further details regarding the
categories of Data processed, the purposes of processing, the categories of
recipients of the personal data, if any, the retention period and further
information about Personal Data can be found in the
section titled “Detailed information on the processing of Personal Data” within
this document.
The rights
of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain
rights regarding their Data within the limits of law, including the following:
· right of
access to Personal Data;
· right to
object to the processing of their Personal Data (which also allows Users to
demand that processing of Personal Data be restricted, Personal Data be deleted
or destroyed, specific disclosures of Personal Data to third parties be
prohibited);
· right to
receive their Personal Data and have it transferred to another controller (data
portability);
· right to
ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User
rights can be directed to the Owner through the contact details provided in
this document. Such requests are free of charge and will be answered by the
Owner as early as possible, providing Users with the information required by
law.
Further
information for Users in Brazil
This part of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the entity running this Application and, if
the case may be, its parent, subsidiaries and affiliates (for the purposes of
this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in
Brazil, according to the "Lei Geral de Proteção de Dados" (Users are
referred to below, simply as “you”, “your”, “yours”). For such Users, these
provisions supersede any other possibly divergent or conflicting provisions
contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined
in the Lei Geral de Proteção de Dados (LGPD).
The grounds
on which we process your personal information
We can process your personal
information solely if we have a legal basis for such processing. Legal bases
are as follows:
· your
consent to the relevant processing activities;
· compliance
with a legal or regulatory obligation that lies with us;
· the
carrying out of public policies provided in laws or regulations or based on
contracts, agreements and similar legal instruments;
· studies
conducted by research entities, preferably carried out on anonymised personal
information;
· the
carrying out of a contract and its preliminary procedures, in cases where you
are a party to said contract;
· the
exercising of our rights in judicial, administrative or arbitration
procedures;
· protection
or physical safety of yourself or a third party;
· the
protection of health – in procedures carried out by health entities or
professionals;
· our
legitimate interests, provided that your fundamental rights and liberties do
not prevail over such interests; and
· credit
protection.
To find out more about the legal
bases, you can contact us at any time using the contact details provided in
this document.
Categories
of personal information processed
To find out what categories of
your personal information are processed, you can read the section titled
“Detailed information on the processing of Personal Data” within this document.
Why we
process your personal information
To find out why we process your
personal information, you can read the sections titled “Detailed information on
the processing of Personal Data” and “The purposes of processing” within this
document.
Your
Brazilian privacy rights, how to file a request and our response to your
requests
Your Brazilian privacy rights
You have the right to:
· obtain
confirmation of the existence of processing activities on your personal
information;
· access to
your personal information;
· have
incomplete, inaccurate or outdated personal information rectified;
· obtain the
anonymization, blocking or elimination of your unnecessary or excessive
personal information, or of information that is not being processed in
compliance with the LGPD;
· obtain
information on the possibility to provide or deny your consent and the
consequences thereof;
· obtain
information about the third parties with whom we share your personal
information;
· obtain,
upon your express request, the portability of your personal information (except
for anonymised information) to another service or product provider, provided
that our commercial and industrial secrets are safeguarded;
· obtain the
deletion of your personal information being processed if the processing was
based upon your consent, unless one or more exceptions provided for in art. 16
of the LGPD apply;
· revoke your
consent at any time;
· lodge a
complaint related to your personal information with the ANPD (the National Data
Protection Authority) or with consumer protection bodies;
· oppose a
processing activity in cases where the processing is not carried out in
compliance with the provisions of the law;
· request
clear and adequate information regarding the criteria and procedures used for
an automated decision; and
· request the
review of decisions made solely on the basis of the automated processing of
your personal information, which affect your interests. These include decisions
to define your personal, professional, consumer and credit profile, or aspects
of your personality.
You will never be discriminated
against, or otherwise suffer any sort of detriment, if you exercise your
rights.
How to file your request
You can file your express
request to exercise your rights free from any charge, at any time, by using the
contact details provided in this document, or via your legal representative.
How and when we will respond to
your request
We will strive to promptly
respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to
communicate to you the factual or legal reasons that prevent us from
immediately, or otherwise ever, complying with your requests. In cases where we
are not processing your personal information, we will indicate to you the
physical or legal person to whom you should address your requests, if we are in
the position to do so.
In the event that you file
an access or personal information processing confirmation request, please make sure
that you specify whether you’d like your personal information to be delivered
in electronic or printed form.
You will also need to let us know whether you want us to answer your request
immediately, in which case we will answer in a simplified fashion, or if you
need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request,
providing you with all the information on the origin of your personal
information, confirmation on whether or not records exist, any criteria used
for the processing and the purposes of the processing, while safeguarding our
commercial and industrial secrets.
In the event that you file
a rectification, deletion, anonymization or personal information
blocking request, we will make sure to immediately communicate
your request to other parties with whom we have shared your personal
information in order to enable such third parties to also comply with your
request – except in cases where such communication is proven impossible or
involves disproportionate effort on our side.
Transfer of
personal information outside of Brazil permitted by the law
We are allowed to transfer your
personal information outside of the Brazilian territory in the following cases:
· when the
transfer is necessary for international legal cooperation between public
intelligence, investigation and prosecution bodies, according to the legal
means provided by the international law;
· when the
transfer is necessary to protect your life or physical security or those of a
third party;
· when the
transfer is authorised by the ANPD;
· when the
transfer results from a commitment undertaken in an international cooperation
agreement;
· when the
transfer is necessary for the execution of a public policy or legal attribution
of public service;
· when the
transfer is necessary for compliance with a legal or regulatory obligation, the
carrying out of a contract or preliminary procedures related to a contract, or
the regular exercise of rights in judicial, administrative or arbitration
procedures.
Further
information for California consumers
This section of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the business running this Application and, if
the case may be, its parent, subsidiaries and affiliates (for the purposes of
this section referred to collectively as “we”, “us”, “our”).
This section applies to all
Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the state of California, United States of America,
according to the "California
Consumer Privacy Act of 2018" (the "CCPA"),
as updated by the "California Privacy Rights Act" (the
"CPRA") and subsequent regulations. For such consumers, this section
supersedes any other possibly divergent or conflicting information contained in
the privacy policy.
This part of the document uses
the term “personal information“ as defined in the California Consumer Privacy
Act (CCPA/CPRA).
Notice at
collection
Categories of personal
information collected, used, sold, or shared
In this section we summarize the
categories of personal information that we've collected, used, sold, or shared
and the purposes thereof. You can read about these
activities in detail in the section titled “Detailed information on the
processing of Personal Data” within this document.
Information
we collect: the categories of personal information we collect
We have collected the following
categories of personal information about you: identifiers and internet or other
electronic network activity information.
We do not collect sensitive
personal information.
We will not collect additional
categories of personal information without notifying you.
What are
the purposes for which we use your personal information?
We may use your personal
information to allow the operational functioning of this Application and
features thereof (“business purposes”). In such cases, your personal
information will be processed in a fashion necessary and proportionate to the
business purpose for which it was collected, and strictly within the limits of
compatible operational purposes.
We may also use your personal
information for other reasons such as for commercial purposes (as indicated
within the section “Detailed information on the processing of Personal Data”
within this document), as well as for complying with the law and defending our
rights before the competent authorities where our rights and interests are
threatened or we suffer an actual damage.
We won’t process your
information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
How long do
we keep your personal information?
Unless stated otherwise inside
the “Detailed information on the processing of Personal Data” section, we will
not retain your personal information for longer than is reasonably necessary
for the purpose(s) they have been collected for.
How we
collect information: what are the sources of the personal information we
collect?
We collect the above-mentioned
categories of personal information, either directly or indirectly, from you
when you use this Application.
For example, you directly
provide your personal information when you submit requests via any forms on
this Application. You also provide personal information indirectly when you
navigate this Application, as personal information about you is automatically
observed and collected.
Finally, we may collect your
personal information from third parties that work with us in connection with
the Service or with the functioning of this Application and features thereof.
How we use
the information we collect: disclosing of your personal information with third
parties for a business purpose
For our purposes, the word
“third party” means a person who is not any of the following: a service
provider or a contractor, as defined by the CCPA.
We disclose your personal
information with the third parties listed in detail in the section
titled “Detailed information on the processing of Personal Data” within this
document. These third parties are grouped and categorized in
accordance with the different purposes of processing.
Sale or
sharing of your personal information
For our purposes, the word
“sale” means any “selling, renting, releasing, disclosing, disseminating,
making available, transferring or otherwise communicating orally, in writing,
or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”,
as defined by the CCPA.
This means that, for example, a
sale can happen whenever an application runs ads, or makes statistical analyses
on the traffic or views, or simply because it uses tools such as social network
plugins and the like.
For our purposes, the word
“sharing” means any “sharing, renting, releasing, disclosing, disseminating,
making available, transferring, or otherwise communicating orally, in writing,
or by electronic or other means, a consumer's personal information by the
business to a third party for cross-context behavioral advertising, whether or
not for monetary or other valuable consideration, including transactions
between a business and a third party for cross-context behavioral advertising
for the benefit of a business in which no money is exchanged”, as defined by
the CCPA.
Please note that the exchange of personal information with a service provider
pursuant to a written contract that meets the requirements set by the CCPA,
does not constitute a sale or sharing of your personal information.
Your right
to opt out of the sale or sharing of your personal information and how you can
exercise it
We sell or share your personal
information with the third parties listed in detail in the section
titled “Detailed information on the processing of Personal Data” within this
document. These third parties are grouped and categorized in
accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal
information. This means that whenever you request us to stop selling or sharing
your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any
verifiable request.
To fully exercise your right to opt out, you can contact us at any time using
the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link
provided on this Application.
If you want to submit requests
to opt out of the sale or sharing of personal information via a user-enabled
global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we
will abide by such request in a frictionless manner (as defined in the CPRA
regulations). The GPC consists of a setting or extension in the browser or
mobile device and acts as a mechanism that websites can use to indicate they
support the GPC signal. If you want to use GPC, you can download and enable it
via a participating
browser or browser extension. More information about downloading GPC is
available here.
We use any personal information
collected from you in connection with the submission of your opt-out request
solely for the purposes of complying with the opt-out request.
Once you have opted out, we are
required to wait at least 12 months before asking whether you have changed your
mind.
Your
privacy rights under the California Consumer Privacy Act and how to exercise
them
The right to access personal
information: the right to know and to portability
You have the right to request
that we disclose to you:
· the
categories of personal information that we collect about you;
· the sources
from which the personal information is collected;
· the
purposes for which we use your information;
· to whom we
disclose such information;
· the
specific pieces of personal information we have collected about you.
You also have the right
to know what personal information is sold or shared and to whom. In
particular, you have the right to request two separate lists from us where we
disclose:
· the
categories of personal information that we sold or shared about you and the
categories of third parties to whom the personal information was sold or
shared;
· the
categories of personal information that we disclosed about you for a business
purpose and the categories of persons to whom it was disclosed for a business
purpose.
The disclosure described above
will be limited to the personal information collected or used over the past 12
months.
If we deliver our response
electronically, the information enclosed will be "portable", i.e.
delivered in an easily usable format to enable you to transmit the information
to another entity without hindrance — provided that this is technically feasible.
The right to request the
deletion of your personal information
You have the right to request
that we delete any of your personal information, subject to exceptions set
forth by the law (such as, including but not limited to, where the information
is used to identify and repair errors on this Application, to detect security
incidents and protect against fraudulent or illegal activities, to exercise
certain rights etc.).
If no legal exception applies,
as a result of exercising your right, we will delete your personal information
and notify any of our service providers and all third parties to whom we have
sold or shared the personal information to do so — provided that this is
technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate
personal information
You have the right to request
that we correct any inaccurate personal information we maintain about you,
taking into account the nature of the personal information and the purposes of
the processing of the personal information.
The right to opt out of sale or
sharing of personal information and to limit the use of your sensitive personal
information
You have the right to opt out of
the sale or sharing of your personal information. You also have the right to
request that we limit our use or disclosure of your sensitive personal
information.
The right of no retaliation
following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against
you for exercising your rights under the CCPA. This means that we will not
discriminate against you, including, but not limited to, by denying goods or
services, charging you a different price, or providing a different level or
quality of goods or services just because you exercised your consumer privacy
rights.
However, if you refuse to
provide your personal information to us or ask us to delete or stop selling
your personal information, and that personal information or sale is necessary
for us to provide you with goods or services, we may not be able to complete
that transaction.
To the extent permitted by the
law, we may offer you promotions, discounts, and other deals in exchange for
collecting, keeping, or selling your personal information, provided that the
financial incentive offered is reasonably related to the value of your personal
information.
How to exercise your rights
To exercise the rights described
above, you need to submit your verifiable request to us by contacting us via
the details provided in this document.
For us to respond to your
request, it’s necessary that we know who you are. Therefore, you can only
exercise the above rights by making a verifiable request which must:
· provide
sufficient information that allows us to reasonably verify you are the person
about whom we collected personal information or an authorized representative;
· describe
your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We will not respond to any
request if we are unable to verify your identity and therefore confirm the
personal information in our possession actually relates to you.
Making a verifiable consumer
request does not require you to create an account with us. We will use any
personal information collected from you in connection with the verification of
your request solely for the purposes of verification and shall not further
disclose the personal information, retain it longer than necessary for purposes
of verification, or use it for unrelated purposes.
If you cannot personally submit
a verifiable request, you can authorize a person registered with the California
Secretary of State to act on your behalf.
If you are an adult, you can
make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number
of 2 requests over a period of 12 months.
How and when we are expected to
handle your request
We will confirm receipt of your
verifiable request within 10 days and provide information about how we will
process your request.
We will respond to your request
within 45 days of its receipt. Should we need more time, we will explain to you
the reasons why, and how much more time we need. In this regard, please note
that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the
preceding 12-month period. Only with regard to personal information collected
on or after January 1, 2022, you have the right to request that we disclose
information beyond the 12-month period, and we will provide them to you unless
doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we
will explain you the reasons behind our denial.
We do not charge a fee to
process or respond to your verifiable request unless such request is manifestly
unfounded or excessive. In such cases, we may charge a reasonable fee, or
refuse to act on the request. In either case, we will communicate our choices
and explain the reasons behind it.
Further
information for Virginia consumers
This section of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the controller running this Application and,
if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all
Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the Commonwealth of Virginia, according to the “Virginia
Consumer Data Protection Act" (the "VCDPA"),
and, for such consumers, it supersedes any other possibly divergent or
conflicting information contained in the privacy policy.
This part of the document uses
the term “personal data” as defined in the VCDPA.
Categories
of personal data processed
In this section, we summarize
the categories of personal data that we've processed and the purposes
thereof. You can read about these activities in detail in the section
titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we
collect
We have collected the following
categories of personal data: identifiers and internet information
We do not collect sensitive
data.
We will not collect additional
categories of personal data without notifying you.
Why we process your personal
data
To find out why we process your
personal data, you can read the sections titled “Detailed information on the
processing of Personal Data” and “The purposes of processing” within this
document.
We won’t process your
information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We share your personal data with
the third parties listed in detail in the section titled “Detailed
information on the processing of Personal Data” within this document. These
third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word "third party" means "a natural or
legal person, public authority, agency, or body other than the consumer,
controller, processor, or an affiliate of the processor or the controller"
as defined by the VCDPA.
Sale of your personal data
For our purposes, the word
“sale” means any “exchange of personal data for monetary consideration by us to
a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a
processor that processes personal data on behalf of a controller does not
constitute a sale. In addition, other specific exceptions set forth in the
VCDPA may apply, such as, but not limited to, the disclosure of personal data
to a third party for the provision of a product or service requested by
you.
As specified in the “Detailed information on the processing of Personal Data”
section of this document, our use of your personal information may be
considered a sale under VCDPA.
Your right
to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of
the sale of your personal data. This means that whenever you request us to stop
selling your data, we will abide by your request. To fully exercise your right
to opt out you can contact us at any time using the contact details provided in
this document.
We use any personal data
collected from you in connection with the submission of your opt-out request
solely for the purpose of complying with the request.
Processing of your personal data
for targeted advertising
We do not process your personal
data for targeted advertising. If we decide to do so, we will inform you
beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
Your
privacy rights under the Virginia Consumer Data Protection Act and how to
exercise them
You may exercise certain rights
regarding your data processed by us. In particular, you have the right to do
the following:
· access
personal data: the right to know. You have the right to
request that we confirm whether or not we are processing your personal data.
You also have the right to access such personal data.
· correct
inaccurate personal data. You have the right to request that we correct
any inaccurate personal data we maintain about you, taking into account the
nature of the personal data and the purposes of the processing of the personal
data.
· request the
deletion of your personal data. You have the right to
request that we delete any of your personal data.
· obtain a
copy of your personal data. We will provide your personal data in a
portable and usable format that allows you to transfer data easily to another
entity — provided that this is technically feasible.
· opt out of
the processing of your personal data for the purposes of targeted advertising, the sale
of personal data, or profilingin furtherance of decisions that
produce legal or similarly significant effects concerning you.
· non-discrimination. We
will not discriminate against you for exercising your rights under the VCDPA.
This means that we will not, among other things, deny goods or services, charge
you a different price, or provide a different level or quality of goods or
services just because you exercised your consumer privacy rights. However, if
you refuse to provide your personal data to us or ask us to delete or stop
selling your personal data, and that personal data or sale is necessary for us
to provide you with goods or services, we may not be able to complete that
transaction. To the extent permitted by the law, we may offer a different
price, rate, level, quality, or selection of goods or services to you,
including offering goods or services for no fee, if you have exercised your right
to opt out, or our offer is related to your voluntary participation in a bona
fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described
above, you need to submit your request to us by contacting us via the contact
details provided in this document.
For us to respond to your
request, we need to know who you are.
We will not respond to any
request if we are unable to verify your identity using commercially reasonable
efforts and therefore confirm that the personal data in our possession actually
relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does
not require you to create an account with us. However, we may require you to
use your existing account. We will use any personal data collected from you in
connection with your request solely for the purposes of authentication, without
further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can
make a request on behalf of a child under your parental authority.
How and when we are expected to
handle your request
We will respond to your request
without undue delay, but in all cases and at the latest within 45 days of its
receipt. Should we need more time, we will explain to you the reasons why, and
how much more time we need. In this regard, please note that we may take up to
90 days to fulfill your request.
Should we deny your request, we
will explain to you the reasons behind our denial without undue delay, but in
all cases and at the latest within 45 days of receipt of the request. It is
your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 60 days of receipt of the appeal, we
will inform you in writing of any action taken or not taken in response to the
appeal, including a written explanation of the reasons for the decisions. If
the appeal is denied you may contact the
Attorney General to submit a complaint.
We do not charge a fee to
respond to your request, for up to two requests per year. If your request is
manifestly unfounded, excessive or repetitive, we may charge a reasonable fee
or refuse to act on the request. In either case, we will communicate our choices
and explain the reasons behind them.
Further
information for Colorado consumers
This section of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the controller running this Application and,
if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all
Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Colorado, according to the “Colorado Privacy
Act" (the "CPA"), and, for such consumers, it supersedes any
other possibly divergent or conflicting information contained in the privacy
policy.
This part of the document uses
the term “personal data” as defined in the CPA.
Categories
of personal data processed
In this section, we summarize
the categories of personal data that we've processed and the purposes
thereof. You can read about these activities in detail in the section
titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we
collect
We have collected the following
categories of personal data: identifiers and internet information
We do not collect sensitive
data.
We will not collect additional
categories of personal data without notifying you.
Why we process your personal
data
To find out why we process your
personal data, you can read the sections titled “Detailed information on the
processing of Personal Data” and “The purposes of processing” within this
document.
We won’t process your
information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We share your personal data with
the third parties listed in detail in the section titled “Detailed
information on the processing of Personal Data” within this document. These
third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word
"third party" means "a person, public authority, agency, or body
other than a consumer, controller, processor, or affiliate of the processor or
the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed
information on the processing of Personal Data” section of this document, our
use of your personal data may be considered a sale under the CPA.
For our purposes, the word
"sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the CPA.
Please note that according to
the CPA, the disclosure of personal data to a processor that processes personal
data on behalf of a controller does not constitute a sale. In addition, other
specific exceptions set forth in the CPA may apply, such as, but not limited
to, the disclosure of personal data to a third party for the provision of a
product or service requested by you.
Your right
to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of
the sale of your personal data. This means that whenever you request us to stop
selling your data, we will abide by your request.
To fully exercise your right to
opt out you can contact us at any time, using the contact details provided in
this document.
For a simplified opt-out method
you can also use the privacy choices link provided on this Application.
We use any personal data
collected from you in connection with the submission of your opt-out request
solely for the purpose of complying with the request.
Processing of your personal data
for targeted advertising
We do not process your personal
data for targeted advertising. If we decide to do so, we will inform you
beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the word
"targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across nonaffiliated websites, applications,
or online services to predict consumer preferences or interests" as
defined by CPA.
Please note that according to the CPA, targeted advertising does not include:
“advertisements directed to a consumer in response to the consumer's request
for information or feedback; advertisements based on activities within a
controller's own websites or online applications or any affiliated website or
online application; advertisements based on the context of a consumer's current
search query, visit to an internet web site or online application; or
processing personal data solely to measure or report advertising frequency,
performance or reach”.
Universal
opt-out mechanism: Global privacy control
If you want to submit requests
to opt-out of the targeted advertising via a user-enabled global privacy
control, like the Global Privacy Control (“GPC”), you are free to do so and we
will abide by such request. The GPC consists of a setting or extension in the
browser or mobile device and acts as a mechanism that websites can use to
indicate they support the GPC signal. If you want to use GPC, you can download
and enable it via a participating browser or browser extension. More
information about downloading GPC is available here.
Your
privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights
regarding your data processed by us. In particular, you have the right to do
the following:
· opt out of
the processing of your personal data for the purposes of targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects concerning you.
· access
personal data. You have the right to request that we confirm whether or not we
are processing your personal data. You also have the right to access such
personal data.
· correct
inaccurate personal data. You have the right to request that we correct any
inaccurate personal data we maintain about you, taking into account the nature
of the personal data and the purposes of the processing of the personal data.
· request the
deletion of your personal data. You have the right to request that we delete
any of your personal data.
· obtain a
copy of your personal data. We will provide your personal data in a portable
and usable format that allows you to transfer data easily to another entity –
provided that this is technically feasible.
In any case, we will not
increase the cost of, or decrease the availability of, a product or service,
based solely on the exercise of any of your rights and unrelated to the
feasibility or the value of a service. However, to the extent permitted by the
law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described
above, you need to submit your request to us by contacting us via the contact
details provided in this document.
For us to respond to your
request, we need to know who you are and which right you wish to exercise.
We will not respond to any
request if we are unable to verify your identity using commercially reasonable
efforts and therefore confirm that the personal data in our possession actually
relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does
not require you to create an account with us. However, we may require you to
use your existing account. We will use any personal data collected from you in
connection with your request solely for the purposes of authentication, without
further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can
make a request on behalf of a child under your parental authority.
How and when we are expected to
handle your request
We will respond to your request
without undue delay, but in all cases and at the latest within 45 days of its receipt.
Should we need more time, we will explain to you the reasons why, and how much
more time we need. In this regard, please note that we may take up to 90 days
to fulfill your request.
Should we deny your request, we
will explain to you the reasons behind our denial without undue delay, but in
all cases and at the latest within 45 days of receipt of the request. It is
your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 45 days of receipt of the appeal, we
will inform you in writing of any action taken or not taken in response to the
appeal, including a written explanation of the reasons for the decisions. If
the appeal is denied you may contact the Attorney General to submit a
complaint.
We do not charge a fee to
respond to your request, for up to two requests per year.
Further
information for Connecticut consumers
This section of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the controller running this Application and,
if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users
(Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Connecticut, according to “An Act Concerning
Personal Data Privacy and Online Monitoring " (also known as "The
Connecticut Data Privacy Act" or the “CTDPA"), and, for such
consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the document uses
the term “personal data” as defined in the CTDPA.
Categories
of personal data processed
In this section, we summarize
the categories of personal data that we've processed and the purposes
thereof. You can read about these activities in detail in the section
titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we
collect
We have collected the following
categories of personal data: identifiers and internet information
We do not collect sensitive
data.
We will not collect additional
categories of personal data without notifying you.
Why we process your personal
data
To find out why we process your
personal data, you can read the sections titled “Detailed information on the
processing of Personal Data” and “The purposes of processing” within this
document.
We won’t process your
information for unexpected purposes, or for purposes incompatible with the
purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We share your personal data with
the third parties listed in detail in the section titled “Detailed
information on the processing of Personal Data” within this document. These
third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word
"third party" means "a person, public authority, agency, or body
other than a consumer, controller, processor, or affiliate of the processor or
the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed
information on the processing of Personal Data” section of this document, our
use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word
"sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the CTDPA.
Please note that according to
the CTDPA, the disclosure of personal data to a processor that processes
personal data on behalf of a controller does not constitute a sale. In
addition, other specific exceptions set forth in the CTDPA may apply, such as,
but not limited to, the disclosure of personal data to a third party for the
provision of a product or service requested by you.
Your right
to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of
the sale of your personal data. This means that whenever you request us to stop
selling your data, we will abide by your request.
To fully exercise your right to
opt out you can contact us at any time, using the contact details provided in
this document.
For a simplified opt-out method
you can also use the privacy choices link provided on this Application.
We use any personal data
collected from you in connection with the submission of your opt-out request
solely for the purpose of complying with the request.
Processing of your personal data
for targeted advertising
We do not process your personal
data for targeted advertising. If we decide to do so, we will inform you
beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the word
"targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across non affiliated websites, applications,
or online services to predict consumer preferences or interests" as
defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include:
“advertisements based on activities within a controller's own web sites or
online applications; advertisements based on the context of a consumer's
current search query, visit to an internet web site or online application;
advertisements directed to a consumer in response to the consumer's request for
information or feedback; or processing personal data solely to measure or
report advertising frequency, performance or reach”.
Universal
opt-out mechanism: Global privacy control
If you want to submit requests
to opt-out of the targeted advertising via a user-enabled global privacy
control, like the Global Privacy Control (“GPC”), you are free to do so and we
will abide by such request. The GPC consists of a setting or extension in the
browser or mobile device and acts as a mechanism that websites can use to
indicate they support the GPC signal. If you want to use GPC, you can download
and enable it via a participating browser or browser extension. More
information about downloading GPC is available here.
Your
privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights
regarding your data processed by us. In particular, you have the right to do
the following:
· access
personal data. You have the right to request that we confirm whether or not we
are processing your personal data. You also have the right to access such
personal data.
· correct
inaccurate personal data. You have the right to request that we correct any
inaccurate personal data we maintain about you, taking into account the nature
of the personal data and the purposes of the processing of the personal data.
· request the
deletion of your personal data. You have the right to request that we delete
any of your personal data.
· obtain a
copy of your personal data. We will provide your personal data in a portable
and usable format that allows you to transfer data easily to another entity –
provided that this is technically feasible.
· opt out of
the processing of your personal data for the purposes of targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects concerning you.
In any case, we will not
increase the cost of, or decrease the availability of, a product or service,
based solely on the exercise of any of your rights and unrelated to the
feasibility or the value of a service. However, to the extent permitted by the
law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described
above, you need to submit your request to us by contacting us via the contact
details provided in this document.
For us to respond to your
request, we need to know who you are and which right you wish to exercise.
We will not respond to any
request if we are unable to verify your identity using commercially reasonable
efforts and therefore confirm that the personal data in our possession actually
relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does
not require you to create an account with us. However, we may require you to
use your existing account. We will use any personal data collected from you in
connection with your request solely for the purposes of authentication, without
further disclosing the personal data, retaining it longer than necessary for
purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can
make a request on behalf of a child under your parental authority.
How and when we are expected to
handle your request
We will respond to your request
without undue delay, but in all cases and at the latest within 45 days of its
receipt. Should we need more time, we will explain to you the reasons why, and
how much more time we need. In this regard, please note that we may take up to
90 days to fulfill your request.
Should we deny your request, we
will explain to you the reasons behind our denial without undue delay, but in
all cases and at the latest within 45 days of receipt of the request. It is
your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 45 days of receipt of the appeal, we
will inform you in writing of any action taken or not taken in response to the
appeal, including a written explanation of the reasons for the decisions. If
the appeal is denied, you may contact the
Attorney General to submit a complaint.
We do not charge a fee to
respond to your request, for up to one request per year.
Further
information for Utah consumers
This section of the document
integrates with and supplements the information contained in the rest of the
privacy policy and is provided by the controller running this Application and,
if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all
Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Utah, according to the “Consumer Privacy
Act" (the “UCPA"), and, for such consumers, it supersedes any other
possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses
the term “personal data” as defined in the UCPA.
Categories
of personal data processed
In this section, we summarize
the categories of personal data that we've processed and the purposes
thereof. You can read about these activities in detail in the section
titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we collect
We have collected the following
categories of personal data: identifiers and internet information
We do not collect sensitive
data.
We will not collect additional
categories of personal data without notifying you.
Why we process your personal
data
To find out why we process your
personal data, you can read the sections titled “Detailed information on the
processing of Personal Data” and “The purposes of processing” within this
document.
How we use the data we collect:
sharing of your personal data with third parties
We share your personal data with
the third parties listed in detail in the section titled “Detailed
information on the processing of Personal Data” within this document. These
third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word
"third party" means "a person other than: the consumer,
controller, or processor; or an affiliate or contractor of the controller or
the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed
information on the processing of Personal Data” section of this document, our
use of your personal data may be considered a sale under the UCPA.
For our purposes, the word
"sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the UCPA.
Please note that according to
the UCPA, the disclosure of personal data to a processor that processes
personal data on behalf of a controller does not constitute a sale. In
addition, other specific exceptions set forth in the UCPA may apply, such as,
but not limited to, the disclosure of personal data to a third party for the
provision of a product or service requested by you.
Your right
to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of
the sale of your personal data. This means that whenever you request us to stop
selling your data, we will abide by your request.
To fully exercise your right to
opt out you can contact us at any time, using the contact details provided in
this document.
For a simplified opt-out method
you can also use the privacy choices link provided on this Application.
We use any personal data
collected from you in connection with the submission of your opt-out request
solely for the purpose of complying with the request.
Processing of your personal data
for targeted advertising
We do not process your personal
data for targeted advertising. If we decide to do so, we will inform you
beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the word
"targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across nonaffiliated websites, applications,
or online services to predict consumer preferences or interests" as
defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include:
“advertisements based on activities within a controller's own websites or
online applications or any affiliated website or online application;
advertisements based on the context of a consumer's current search query, visit
to an web site or online application; advertisements directed to a consumer in
response to the consumer's request for information, product, a service or
feedback; or processing personal data solely to measure or report advertising
performance, reach or frequency.”
Your
privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights
regarding your data processed by us. In particular, you have the right to do
the following:
· access
personal data. You have the right to request that we confirm whether or not we
are processing your personal data. You also have the right to access such
personal data.
· request the
deletion of your personal data. You have the right to request that we delete
any of your personal data.
· obtain a
copy of your personal data. We will provide your personal data in a portable
and usable format that allows you to transfer data easily to another entity –
provided that this is technically feasible.
· opt out of
the processing of your personal data for the purposes of targeted advertising
or the sale of personal data.
In any case, we will not
increase the cost of, or decrease the availability of, a product or service,
based solely on the exercise of any of your rights and unrelated to the
feasibility or the value of a service. However, to the extent permitted by the
law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described
above, you need to submit your request to us by contacting us via the contact
details provided in this document.
For us to respond to your
request, we need to know who you are and which right you wish to exercise.
We will not respond to any
request if we are unable to verify your identity using commercially reasonable
efforts and therefore confirm that the personal data in our possession actually
relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
We may retain your email address to respond to your request.
If you are an adult, you can
make a request on behalf of a child under your parental authority.
How and when we are expected to
handle your request
We will respond to your request
without undue delay, but in all cases and at the latest within 45 days of its
receipt. Should we need more time, we will explain to you the reasons why, and
how much more time we need. In this regard, please note that we may take up to
90 days to fulfill your request.
Should we deny your request, we
will explain to you the reasons behind our denial without undue delay, but in
all cases and at the latest within 45 days of receipt of the request.
We do not charge a fee to
respond to your request, for up to one request per year.
Additional
information about Data collection and processing
Legal
action
The User's Personal Data may be
used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Application or the
related Services.
The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities.
Additional
information about User's Personal Data
In addition to the information
contained in this privacy policy, this Application may provide the User with additional
and contextual information concerning particular Services or the collection and
processing of Personal Data upon request.
System logs
and maintenance
For operation and maintenance
purposes, this Application and any third-party services may collect files that
record interaction with this Application (System logs) or use other Personal
Data (such as the IP Address) for this purpose.
Information
not contained in this policy
More details concerning the
collection or processing of Personal Data may be requested from the Owner at
any time. Please see the contact information at the beginning of this document.
Changes to
this privacy policy
The Owner reserves the right to
make changes to this privacy policy at any time by notifying its Users on this
page and possibly within this Application and/or - as far as technically and
legally feasible - sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often,
referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the
User’s consent, the Owner shall collect new consent from the User, where
required.
Definitions and legal references
Personal
Data (or Data)
Any
information that directly, indirectly, or in connection with other information
— including a personal identification number — allows for the identification or
identifiability of a natural person.
Usage Data
Information
collected automatically through this Application (or third-party services
employed in this Application), which can include: the IP addresses or domain
names of the computers utilised by the Users who use this Application, the URI
addresses (Uniform Resource Identifier), the time of the request, the method
utilised to submit the request to the server, the size of the file received in
response, the numerical code indicating the status of the server's answer
(successful outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilised by the User, the various time details
per visit (e.g., the time spent on each page within the Application) and the
details about the path followed within the Application with special reference
to the sequence of pages visited, and other parameters about the device
operating system and/or the User's IT environment.
User
The
individual using this Application who, unless otherwise specified, coincides
with the Data Subject.
Data
Subject
The natural
person to whom the Personal Data refers.
Data
Processor (or Processor)
The natural
or legal person, public authority, agency or other body which processes
Personal Data on behalf of the Controller, as described in this privacy policy.
Data
Controller (or Owner)
The natural
or legal person, public authority, agency or other body which, alone or jointly
with others, determines the purposes and means of the processing of Personal
Data, including the security measures concerning the operation and use of this
Application. The Data Controller, unless otherwise specified, is the Owner of
this Application.
This
Application
The means
by which the Personal Data of the User is collected and processed.
Service
The service
provided by this Application as described in the relative terms (if available)
and on this site/application.
European
Union (or EU)
Unless
otherwise specified, all references made within this document to the European
Union include all current member states to the European Union and the European
Economic Area.
Cookie
Cookies are
Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker
indicates any technology - e.g Cookies, unique identifiers, web beacons,
embedded scripts, e-tags and fingerprinting - that enables the tracking of
Users, for example by accessing or storing information on the User’s device.
Legal
information
This
privacy statement has been prepared based on provisions of multiple
legislations.
This
privacy policy relates solely to this Application, if not stated otherwise
within this document.
Latest update: 12 March 2024