Privacy Policy of projectleannation.com
This Application collects some Personal Data from its Users.
This document contains a section dedicated to Users in the United States 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.
Policy summary
Personal Data processed for the following purposes and using the following services:
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Access to third-party accounts
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Facebook account access
Permissions: Tracker
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Advertising
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Meta ads conversion tracking (Meta pixel) and Google Ads conversion tracking
Personal Data: Trackers; Usage Data
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Facebook Audience Network and AdMob
Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
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Facebook Lookalike Audience, Google Ad Manager and Google Ads Similar audiences
Personal Data: Tracker; Usage Data
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Direct marketing via SMS
Personal Data: first name; last name; phone number
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Analytics
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Google Analytics for Firebase and User ID extension for Google Analytics
Personal Data: Tracker
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Google Analytics (Universal Analytics), Analytics collected directly and YouTube Analytics and Reporting API
Personal Data: Tracker; Usage Data
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Facebook Analytics for Apps
Personal Data: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service
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Google Analytics Advertising Reporting Features
Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service
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Google Analytics Demographics and Interests reports
Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
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PostHog product analytics
Personal Data: browser information; browsing history; city; clicks; country; device information; email address; first name; IP address; last name; page views; province; state; Trackers; username
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Google Analytics 4
Personal Data: number of Users; session statistics; Trackers; Usage Data
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Meta Events Manager
Personal Data: browsing history; clicks; email address; IP address; phone number; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; ZIP/Postal code
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Beta Testing
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Google Play Beta Testing
Personal Data: Tracker
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Contacting the User
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Contact form
Personal Data: city; country; email address; first name; last name; phone number; physical address; state; various types of Data; ZIP/Postal code
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Content commenting
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Facebook Comments
Personal Data: Tracker; Usage Data
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Content performance and features testing (A/B testing)
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Firebase Remote Config
Personal Data: various types of Data as specified in the privacy policy of the service
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Google Optimize and Google Optimize 360
Personal Data: Tracker; Usage Data
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PostHog feature flags and A/B testing
Personal Data: browser information; city; country; device information; email address; first name; IP address; last name; latitude (of city); longitude (of city); operating systems; page views; referral URL; state; time zone; Trackers; Usage Data; username; ZIP/Postal code
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Displaying content from external platforms
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Google Fonts
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
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Google Maps widget and YouTube video widget
Personal Data: Tracker; Usage Data
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YouTube Data API
Personal Data: Data communicated in order to use the Service; Data communicated while using the service; Tracker; Usage Data
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YouTube IFrame Player
Personal Data: Data communicated in order to use the Service; Data communicated while using the service; device information; Tracker; Usage Data
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Handling activities related to productivity
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Zoho projects
Personal Data: Data communicated while using the service; Tracker; Usage Data
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Heat mapping and session recording
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PostHog session replay
Personal Data: city; clicks; company name; country; Data communicated while using the service; device information; email address; first name; geographic position; IP address; last name; operating systems; page views; Trackers; Usage Data; User ID
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Hosting and backend infrastructure
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Amazon Web Services (AWS)
Personal Data: various types of Data as specified in the privacy policy of the service
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Vercel
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
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Infrastructure monitoring
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Firebase Performance Monitoring
Personal Data: various types of Data as specified in the privacy policy of the service
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Crashlytics
Personal Data: crash data; device information; Universally unique identifier (UUID)
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Interaction with live chat platforms
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Facebook Messenger Customer Chat
Personal Data: Data communicated while using the service; Tracker; Usage Data
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Managing contacts and sending messages
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Firebase Cloud Messaging
Personal Data: various types of Data as specified in the privacy policy of the service
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Sendgrid and ZOHO Campaigns
Personal Data: Tracker
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Twilio
Personal Data: phone number
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Managing support and contact requests
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ZOHO CRM Email
Personal Data: Tracker
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Platform services and hosting
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Google Play Store
Personal Data: Usage Data
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Remarketing and behavioral targeting
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Facebook Custom Audience
Personal Data: email address; Tracker
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Facebook Remarketing, Google Ad Manager Audience Extension, Google Ads Remarketing and Remarketing with Google Analytics
Personal Data: Tracker; Usage Data
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Social features
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Firebase Dynamic Links
Personal Data: various types of Data as specified in the privacy policy of the service
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Tag Management
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Google Tag Manager
Personal Data: Tracker
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User database management
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ZOHO CRM
Personal Data: Tracker
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Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application. -
Push notifications based on the User's geographic location
This Application may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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Push notifications for direct marketing
This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
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Contact information
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Owner and Data Controller
Project LeanNation Inc.
1900 S Clinton Ave.
Rochester, NY 14618Owner contact email: info@projectleannation.com
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Full policy
Owner and Data Controller
Project LeanNation Inc.
1900 S Clinton Ave.
Rochester, NY 14618
Owner contact email: info@projectleannation.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; phone number; physical address; country; state; email address; ZIP/Postal code; various types of Data; city; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service; Universally unique identifier (UUID); crash data; device information; Data communicated in order to use the Service; username; IP address; browser information; page views; operating systems; referral URL; latitude (of city); longitude (of city); time zone; clicks; geographic position; User ID; company name; province; browsing history; number of Users; session statistics.
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 unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this 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: Infrastructure monitoring, Content performance and features testing (A/B testing), Analytics, Social features, Managing contacts and sending messages, Displaying content from external platforms, Contacting the User, Advertising, Remarketing and behavioral targeting, Interaction with live chat platforms, Content commenting, Access to third-party accounts, Beta Testing, Platform services and hosting, Tag Management, Hosting and backend infrastructure, User database management, Managing support and contact requests, Handling activities related to productivity and Heat mapping and session recording.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
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.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.Facebook account access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Lookalike Audience (Facebook, Inc.)
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Application or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ad Manager (Google LLC)
Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ads conversion tracking (Google LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Ads Similar audiences (Google LLC)
Similar audiences is an advertising and behavioral targeting service provided by Google LLC that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.Users who don't want to be included in Similar audiences can opt out and disable the use of advertising cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AdMob (Google LLC)
AdMob is an advertising service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Direct marketing via SMS (this Application)
This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application.
Personal Data processed: first name; last name; phone number.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sharing in California
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics for Firebase (Google LLC)
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes 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 contextualize and personalize the ads of its own advertising network.In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Analytics Demographics and Interests reports (Google LLC)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
User ID extension for Google Analytics (Google LLC)
Google Analytics on this Application makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Application.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Analytics collected directly (this Application)
This Application uses an internal analytics system that does not involve third parties.
Personal Data processed: Tracker; Usage Data.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
YouTube Analytics and Reporting API (Google LLC)
YouTube Analytics and Reporting API is a video content analytics service provided by Google LLC.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
PostHog product analytics (PostHog, Inc.)
PostHog product analytics is an analytics service provided by PostHog, Inc. that gives the Owner insight into the use of this Application by Users.
Personal Data processed: browser information; browsing history; city; clicks; country; device information; email address; first name; IP address; last name; page views; province; state; Trackers; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.
Personal Data processed: browsing history; clicks; email address; IP address; phone number; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; ZIP/Postal code.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
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Beta Testing
This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.Google Play Beta Testing (Google LLC)
Google Play Beta Testing is a beta testing service provided by Google LLC.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: city; country; email address; first name; last name; phone number; physical address; state; various types of Data; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.
Firebase Remote Config (Google LLC)
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Optimize 360 (Google LLC)
Google Optimize 360 is an A/B testing service provided by Google LLC ("Google").
This service allows the Owner to target groups of Users on the base of their past use of this Application. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
PostHog feature flags and A/B testing (PostHog, Inc.)
PostHog feature flags and A/B testing is a feature flags and A/B testing service provided by PostHog, Inc.
Personal Data processed: browser information; city; country; device information; email address; first name; IP address; last name; latitude (of city); longitude (of city); operating systems; page views; referral URL; state; time zone; Trackers; Usage Data; username; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; geolocation data.
This processing constitutes:
- a Sale in the United States
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Google Maps widget (Google LLC)
Google Maps is a maps visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
YouTube Data API (Google LLC)
YouTube Data API is a video content visualization service provided by Google LLC that allows this Application to incorporate functions normally executed on YouTube so that Users can watch, find, and manage YouTube content directly on this Application.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of Trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
YouTube IFrame Player (Google LLC)
YouTube IFrame Player is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Through this Service, this Application may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; device information; Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Handling activities related to productivity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.Zoho projects (Zoho Corporation Pvt. Ltd.)
Zoho projects is a project management service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Heat mapping and session recording
Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior. Some of these services may record sessions and make them available for later visual playback.
PostHog session replay (PostHog, Inc.)
PostHog session replay is a session recording service provided by PostHog, Inc.
Personal Data processed: city; clicks; company name; country; Data communicated while using the service; device information; email address; first name; geographic position; IP address; last name; operating systems; page views; Trackers; Usage Data; User ID.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information; geolocation data.
This processing constitutes:
- a Sale in the United States
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Vercel (Vercel Inc.)
Vercel is a hosting and backend service provided by Vercel Inc.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
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Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.Firebase Performance Monitoring (Google LLC)
Firebase Performance Monitoring is a monitoring service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Crashlytics (Google LLC)
Crashlytics is a monitoring service provided by Google LLC.
Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.Facebook Messenger Customer Chat (Facebook, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.Firebase Cloud Messaging (Google LLC)
Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
Twilio (Twilio, Inc.)
Twilio is a phone numbers management and communication service provided by Twilio, Inc.
Personal Data processed: phone number.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in California
- a Sharing in California
ZOHO Campaigns (Zoho Corporation Pvt. Ltd.)
ZOHO Campaigns is an email address management and message sending service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).ZOHO CRM Email (Zoho Corporation Pvt. Ltd.)
ZOHO CRM Email is a support and contact request management service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.Google Play Store (Google LLC)
This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ad Manager Audience Extension (Google LLC)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Social features
Firebase Dynamic Links (Google LLC)
Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.ZOHO CRM (Zoho Corporation Pvt. Ltd.)
ZOHO CRM is a User database management service provided by Zoho Corporation Pvt. Ltd.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application. -
Push notifications based on the User's geographic location
This Application may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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Push notifications for direct marketing
This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for this Application or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.
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.
Further information for Users in Brazil
This section 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”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the 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 anonymized 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 anonymized 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 authorized 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 Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed: various types of Data as specified in the privacy policy of the service, Tracker, Usage Data, first name, last name, phone number, physical address, country, state, email address, ZIP/Postal code, various types of Data, city, Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Data communicated while using the service, Universally unique identifier (UUID), crash data, device information, Data communicated in order to use the Service, IP address, browser information, page views, operating systems, referral URL, latitude (of city), longitude (of city), time zone, clicks, geographic position, User ID, company name, province, browsing history, number of Users, session statistics
Sensitive Personal Information collected or disclosed ℹ️: username
Purposes:
- Infrastructure monitoring
- Content performance and features testing (A/B testing)
- Analytics
- Further information about Personal Data
- Social features
- Managing contacts and sending messages
- Displaying content from external platforms
- Contacting the User
- Advertising
- Remarketing and behavioral targeting
- Interaction with live chat platforms
- Content commenting
- Access to third-party accounts
- Beta Testing
- Platform services and hosting
- Tag Management
- Hosting and backend infrastructure
- User database management
- Managing support and contact requests
- Handling activities related to productivity
- Heat mapping and session recording
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: Yes
Third-parties: Google LLC, Meta Platforms, Inc., Facebook, Inc., Sendgrid, Amazon Web Services, Inc., Zoho Corporation Pvt. Ltd., PostHog, Inc., Vercel Inc.
Service providers or contractors: this Application
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Identifiers
Personal Information collected or disclosed: first name, last name, phone number, physical address, country, state, email address, ZIP/Postal code, various types of Data, city, Tracker, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Universally unique identifier (UUID), crash data, device information, Trackers, IP address, browser information, page views, operating systems, referral URL, latitude (of city), longitude (of city), time zone, clicks, geographic position, Data communicated while using the service, User ID, company name, province, browsing history
Sensitive Personal Information collected or disclosed ℹ️: username
Purposes:
- Contacting the User
- Remarketing and behavioral targeting
- Advertising
- Analytics
- Infrastructure monitoring
- Managing contacts and sending messages
- Content performance and features testing (A/B testing)
- Heat mapping and session recording
- Hosting and backend infrastructure
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: Yes
Third-parties: Facebook, Inc., Google LLC, Twilio, Inc., PostHog, Inc., Vercel Inc., Meta Platforms, Inc.
Service providers or contractors: this Application
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Geolocation data
Personal Information collected or disclosed: Trackers, first name, last name, IP address, device information, browser information, email address, city, state, country, page views, Usage Data, operating systems, referral URL, latitude (of city), longitude (of city), ZIP/Postal code, time zone, clicks, geographic position, Data communicated while using the service, User ID, company name
Sensitive Personal Information collected or disclosed ℹ️: username
Purposes:
- Content performance and features testing (A/B testing)
- Heat mapping and session recording
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: Yes
Third-parties: PostHog, Inc.
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Commercial information
Personal Information collected or disclosed: Trackers, first name, last name, IP address, device information, email address, city, country, page views, clicks, Usage Data, operating systems, geographic position, Data communicated while using the service, User ID, company name
Purposes:
- Heat mapping and session recording
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: Yes
Targeted Advertising: ℹ️: Yes
Third-parties: PostHog, Inc.
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this 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.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this 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) / Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this 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.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
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: September 16, 2024