Política de privacidad
Privacy Policy of Cryptoguru
In order to receive
information about your Personal Data, the purposes and the parties the Data is
shared with, contact the Owner.
Owner and Data
Controller
Clickfun Limited
Favieru 6,MAIROZA
COURT 6, Flat/Office 1, Limassol, Cyprus, 3107
Owner contact email: help@cryptoguru.one
Types of Data collected
The owner does not
provide a list of Personal Data types collected.
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.
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.
Futher information
for California consumers
This section of the
document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by the business running this Application
and, if the case may be, its parent, subsidiaries and
affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to
all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the state of California, United States of America, according
to the "California Consumer Privacy Act of
2018" (the "CCPA"), as updated by
the "California Privacy Rights Act" (the "CPRA") and
subsequent regulations. For such consumers, this section supersedes any other
possibly divergent or conflicting information contained in the privacy policy.
This part of the
document uses the term “personal information“ as
defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
Categories of personal
information collected, used, sold, or shared
In this
section we summarize the categories of personal information that we've
collected, used, sold, or shared and the purposes thereof. You can read
about these activities in detail in the section titled “Detailed information on
the processing of Personal Data” within this document.
Information we collect: the categories of
personal information we collect
We have collected the
following categories of personal information about you: .
We do not collect
sensitive personal information.
We will not collect
additional categories of personal information without notifying you.
What are the purposes for which we use your
personal information?
We may use your
personal information to allow the operational functioning of this Application
and features thereof (“business
purposes”). In such cases, your personal information will be processed in a
fashion necessary and proportionate to the business purpose for which it was
collected, and strictly within the limits of compatible operational purposes.
We may also use your
personal information for other reasons such as for commercial purposes (as
indicated within the section “Detailed
information on the processing of Personal Data” within this document), as well
as for complying with the law and defending our rights before the competent
authorities where our rights and interests are threatened
or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for
purposes incompatible with the purposes originally disclosed, without your
consent.
How long do we keep your personal information?
Unless stated otherwise
inside the “Detailed
information on the processing of Personal Data” section, we will not retain
your personal information for longer than is reasonably necessary for the
purpose(s) they have been collected for.
How we collect information: what are the
sources of the personal information we collect?
We collect the
above-mentioned categories of personal information, either directly or
indirectly, from you when you use this Application.
For example, you
directly provide your personal information when you submit requests via any
forms on this Application. You also provide personal information indirectly
when you navigate this Application, as personal information about you is
automatically observed and collected.
How we use the information we collect:
disclosing of your personal information with third parties for a business
purpose
We do not disclose your
personal information to third parties. For our purposes, the word “third party” means “a person who is not any
of the following: a service provider or a contractor, as defined by the CCPA.
No sale of your
personal information
We do not sell or share
your personal information. In case we should decide to, we will inform you
beforehand and will grant your right to opt out of such sale.
Your privacy rights
under the California Consumer Privacy Act and how to exercise them
The right to access
personal information: the right to know and to portability
You have the right to
request that we disclose to you:
•
the categories of personal information that we
collect about you;
•
the sources from which the personal information
is collected;
•
the purposes for which we use your information;
•
to whom we disclose such information;
•
the specific pieces of personal information we
have collected about you.
You also have the right to know what personal information is sold or shared and
to whom. In particular, you have the right
to request two separate lists from us where we disclose:
•
the categories of personal information that we
sold or shared about you and the categories of third parties to whom the
personal information was sold or shared;
•
the categories of personal information that we
disclosed about you for a business purpose and the categories of persons to
whom it was disclosed for a business purpose.
The disclosure
described above will be limited to the personal information collected or used
over the past 12 months.
If we deliver our
response electronically, the information enclosed will be "portable",
i.e. delivered in an easily usable format to enable
you to transmit the information to another entity without hindrance — provided
that this is technically feasible.
The right to request
the deletion of your personal information
You have the right to
request that we delete any of your personal information, subject to exceptions
set forth by the law (such as, including but not limited to, where the
information is used to identify and repair errors on this Application, to
detect security incidents and protect against fraudulent or illegal activities,
to exercise certain rights etc.).
If no legal exception
applies, as a result of exercising your right, we will
delete your personal information and notify any of our service providers and
all third parties to whom we have sold or shared the personal information to do
so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct
inaccurate personal information
You have the right to
request that we correct any inaccurate personal information we maintain about
you, taking into account the nature of the personal
information and the purposes of the processing of the personal information.
The right to opt out of
sale or sharing of personal information and to limit the use of your sensitive
personal information
You have the right to
opt out of the sale or sharing of your personal information. You also have the
right to request that we limit our use or disclosure of your sensitive personal
information.
The right of no
retaliation following opt-out or exercise of other rights (the right to
non-discrimination)
We will not
discriminate against you for exercising your rights under the CCPA. This means
that we will not discriminate against you, including, but not limited to, by
denying goods or services, charging you a different price, or providing a
different level or quality of goods or services just because you exercised your
consumer privacy rights.
However, if you refuse
to provide your personal information to us or ask us to delete or stop selling
your personal information, and that personal information or sale is necessary
for us to provide you with goods or services, we may not be able to complete
that transaction.
To the extent permitted
by the law, we may offer you promotions, discounts, and other deals in exchange
for collecting, keeping, or selling your personal information, provided that
the financial incentive offered is reasonably related to the value of your
personal information.
How to exercise your
rights
To exercise the rights
described above, you need to submit your verifiable request to us by contacting
us via the details provided in this document.
For us to respond to
your request, it’s necessary that we
know who you are. Therefore, you can only exercise the above rights by making a
verifiable request which must:
•
provide sufficient information that allows us
to reasonably verify you are the person about whom we collected personal
information or an authorized representative;
•
describe your request with sufficient detail
that allows us to properly understand, evaluate, and respond to it.
We will not respond to
any request if we are unable to verify your identity and therefore confirm the
personal information in our possession actually relates
to you.
Making a verifiable
consumer request does not require you to create an account with us. We will use
any personal information collected from you in connection with the verification
of your request solely for the purposes of verification and shall not further
disclose the personal information, retain it longer than necessary for purposes
of verification, or use it for unrelated purposes.
If you cannot
personally submit a verifiable request, you can authorize a person registered
with the California Secretary of State to act on your behalf.
If you are an adult,
you can make a verifiable request on behalf of a child under your parental
authority.
You can submit a
maximum number of 2 requests over a period of 12 months.
How and when we are
expected to handle your request
We will confirm receipt
of your verifiable request within 10 days and provide information about how we
will process your request.
We will respond to your
request within 45 days of its receipt. Should we need more time, we will
explain to you the reasons why, and how much more time we need. In this regard,
please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will
cover the preceding 12-month period. Only with regard to
personal information collected on or after January 1, 2022, you have the right
to request that we disclose information beyond the 12-month period, and we will
provide them to you unless doing so proves impossible or would involve a
disproportionate effort.
Should we deny your
request, we will explain you the reasons behind our denial.
We do not charge a fee
to process or respond to your verifiable request unless such request is
manifestly unfounded or excessive. In such cases, we may charge a reasonable
fee, or refuse to act on the request. In either case, we will communicate our
choices and explain the reasons behind it.
Further information for
Virginia consumers
This section of the
document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by the controller running this
Application and, if the case may be, its parent, subsidiaries
and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to
all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection
Act" (the "VCDPA"), and, for such
consumers, it supersedes any other possibly divergent or conflicting
information contained in the privacy policy.
This part of the
document uses the term “personal data” as defined in the VCDPA.
Categories of personal
data processed
In this
section, we summarize the categories of personal data that we've processed and
the purposes thereof. You can read about these activities in detail
in the section titled “Detailed
information on the processing of Persona Data” within this document.
Categories of personal
data we collect
We have collected the
following categories of personal data:
We do not collect
sensitive data.
We will not collect
additional categories of personal data without notifying you.
Why we process your personal
data
To find out why we
process your personal data, you can read the sections titled “Detailed information on
the processing of Personal Data” and “The purposes
of processing” within this document.
We won’t process your information for unexpected purposes, or for
purposes incompatible with the purposes originally disclosed, without your
consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We do not share nor
disclose your personal data with third parties.
Sale of your personal
data
We do not sell your
personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
Processing of your
personal data for targeted advertising
We do not process your
personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
Your privacy rights
under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise
certain rights regarding your data processed by us. In
particular, you have the right to do the following:
•
access personal data:
the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You
also have the right to access such personal data.
•
correct inaccurate
personal data. You have the right to request that we correct
any inaccurate personal data we maintain about you, taking
into account the nature of the personal data and the purposes of the
processing of the personal data.
•
request the deletion of
your personal data. You have the right to request that we delete
any of your personal data.
•
obtain a copy of your
personal data. We will provide your personal data in a
portable and usable format that allows you to transfer data easily to another
entity — provided that this is technically feasible.
•
opt out of the
processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects
concerning you.
•
non-discrimination. We will not
discriminate against you for exercising your rights under the VCDPA. This means
that we will not, among other things, deny goods or services, charge you a
different price, or provide a different level or quality of goods or services
just because you exercised your consumer privacy rights. However, if you refuse
to provide your personal data to us or ask us to delete or stop selling your
personal data, and that personal data or sale is necessary for us to provide
you with goods or services, we may not be able to complete that transaction. To
the extent permitted by the law, we may offer a different price, rate, level,
quality, or selection of goods or services to you, including offering goods or
services for no fee, if you have exercised your right to opt out, or our offer
is related to your voluntary participation in a bona fide loyalty, rewards,
premium features, discounts, or club card program.
How to exercise your
rights
To exercise the rights
described above, you need to submit your request to us by contacting us via the
contact details provided in this document.
For us to respond to
your request, we need to know who you are.
We will not respond to
any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our
possession actually relate to you. In such cases, we
may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer
request does not require you to create an account with us. However, we may
require you to use your existing account. We will use any personal data
collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it
longer than necessary for purposes of authentication, or using it for unrelated
purposes.
If you are an adult,
you can make a request on behalf of a child under your parental authority.
How and when we are
expected to handle your request
We will respond to your
request without undue delay, but in all cases and at the latest within 45 days
of its receipt. Should we need more time, we will explain to you the reasons
why, and how much more time we need. In this regard, please note that we may
take up to 90 days to fulfill your request.
Should we deny your
request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the
request. It is your right to appeal such decision by submitting a request to us
via the details provided in this document. Within 60 days of receipt of the
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions. If the appeal is denied you may contact the Attorney General to
submit a complaint.
We do not charge a fee
to respond to your request, for up to two requests per year. If your request is
manifestly unfounded, excessive or repetitive, we may
charge a reasonable fee or refuse to act on the request. In either case, we
will communicate our choices and explain the reasons behind them.
Further information for
Colorado consumers
This section of the
document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by the controller running this
Application and, if the case may be, its parent, subsidiaries
and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to
all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Colorado, according to the “Colorado Privacy
Act" (the "CPA"), and, for such consumers, it supersedes any
other possibly divergent or conflicting information contained in the privacy
policy.
This part of the
document uses the term “personal data” as defined in the CPA.
Categories of personal
data processed
In this
section, we summarize the categories of personal data that we've processed and
the purposes thereof. You can read about these activities in detail
in the section titled “Detailed
information on the processing of Persona Data” within this document.
Categories of personal
data we collect
We have collected the
following categories of personal data:
We do not collect
sensitive data.
We will not collect
additional categories of personal data without notifying you.
Why we process your personal
data
To find out why we
process your personal data, you can read the sections titled “Detailed information on
the processing of Personal Data” and “The purposes
of processing” within this document.
We won’t process your information for unexpected purposes, or for
purposes incompatible with the purposes originally disclosed, without your
consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We do not share nor
disclose your personal data with third parties.
For our purposes, the word "third party" means "a natural or
legal person, public authority, agency, or body other than the consumer,
controller, processor, or an affiliate of the processor or the controller"
as defined by the VCDPA.
For our purposes, the
word "third party" means "a person, public authority, agency, or
body other than a consumer, controller, processor, or affiliate of the
processor or the controller." as defined by the CPA.
Sale of your personal
data
We do not sell your
personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the
word "sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the CPA.
Please note that
according to the CPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale.
In addition, other specific exceptions set forth in the CPA may apply, such as,
but not limited to, the disclosure of personal data to a third party for the
provision of a product or service requested by you.
Processing of your
personal data for targeted advertising
We do not process your
personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the
word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across nonaffiliated websites, applications,
or online services to predict consumer preferences or interests" as
defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed
to a consumer in response to the consumer's request for information or
feedback; advertisements based on activities within a controller's own websites
or online applications or any affiliated website or online application;
advertisements based on the context of a consumer's current search query, visit
to an internet web site or online application; or processing personal data
solely to measure or report advertising frequency, performance or reach”.
Your privacy rights
under the Colorado Privacy Act and how to exercise them
You may exercise
certain rights regarding your data processed by us. In
particular, you have the right to do the following:
•
opt out of the processing of your personal data
for the purposes of targeted advertising, the sale of personal data, or
profiling in furtherance of decisions that produce legal or similarly
significant effects concerning you.
•
access personal data. You have the right to
request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal
data.
•
correct inaccurate personal data. You have the
right to request that we correct any inaccurate personal data we maintain about
you, taking into account the nature of the personal
data and the purposes of the processing of the personal data.
•
request the deletion of your personal data. You
have the right to request that we delete any of your personal data.
•
obtain a copy of your personal data. We will
provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that
this is technically feasible.
In any case, we will
not increase the cost of, or decrease the availability of, a product or
service, based solely on the exercise of any of your rights and unrelated to
the feasibility or the value of a service. However, to the extent permitted by
the law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your
rights
To exercise the rights
described above, you need to submit your request to us by contacting us via the
contact details provided in this document.
For us to respond to
your request, we need to know who you are and which right you wish to exercise.
We will not respond to
any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our
possession actually relate to you. In such cases, we
may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer
request does not require you to create an account with us. However, we may
require you to use your existing account. We will use any personal data
collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it
longer than necessary for purposes of authentication, or using it for unrelated
purposes.
If you are an adult,
you can make a request on behalf of a child under your parental authority.
How and when we are
expected to handle your request
We will respond to your
request without undue delay, but in all cases and at the latest within 45 days
of its receipt. Should we need more time, we will explain to you the reasons
why, and how much more time we need. In this regard, please note that we may
take up to 90 days to fulfill your request.
Should we deny your
request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the
request. It is your right to appeal such decision by submitting a request to us
via the details provided in this document. Within 45 days of receipt of the
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions. If the appeal is denied you may contact the Attorney General to
submit a complaint.
We do not charge a fee
to respond to your request, for up to two requests per year.
Further information for
Connecticut consumers
This section of the
document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by the controller running this
Application and, if the case may be, its parent, subsidiaries
and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Connecticut, according to “An Act Concerning
Personal Data Privacy and Online Monitoring " (also known as "The
Connecticut Data Privacy Act" or the “CTDPA"),
and, for such consumers, it supersedes any other possibly divergent or
conflicting information contained in the privacy policy.
This part of the
document uses the term “personal data” as defined in the CTDPA.
Categories of personal
data processed
In this
section, we summarize the categories of personal data that we've processed and
the purposes thereof. You can read about these activities in detail
in the section titled “Detailed
information on the processing of Persona Data” within this document.
Categories of personal
data we collect
We have collected the
following categories of personal data:
We do not collect
sensitive data.
We will not collect
additional categories of personal data without notifying you.
Why we process your personal
data
To find out why we
process your personal data, you can read the sections titled “Detailed information on
the processing of Personal Data” and “The purposes
of processing” within this document.
We won’t process your information for unexpected purposes, or for
purposes incompatible with the purposes originally disclosed, without your
consent.
You can freely give, deny, or withdraw such consent at any time using the
contact details provided in this document.
How we use the data we collect:
sharing of your personal data with third parties
We do not share nor
disclose your personal data with third parties.
For our purposes, the
word "third party" means "a person, public authority, agency, or
body other than a consumer, controller, processor, or affiliate of the
processor or the controller." as defined by the CTDPA.
Sale of your personal
data
We do not sell your
personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the
word "sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the CTDPA.
Please note that
according to the CTDPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale.
In addition, other specific exceptions set forth in the CTDPA may apply, such
as, but not limited to, the disclosure of personal data to a third party for
the provision of a product or service requested by you.
Processing of your
personal data for targeted advertising
We do not process your
personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the
word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across non affiliated websites, applications, or online
services to predict consumer preferences or interests" as defined by
CTDPA.
Please note that according to the CTDPA, targeted advertising does not include:
“advertisements based on
activities within a controller's own web sites or online applications;
advertisements based on the context of a consumer's current search query, visit
to an internet web site or online application; advertisements directed to a consumer
in response to the consumer's request for information or feedback; or
processing personal data solely to measure or report advertising frequency,
performance or reach”.
Your privacy rights
under the Connecticut Data Privacy Act and how to exercise them
You may exercise
certain rights regarding your data processed by us. In
particular, you have the right to do the following:
•
access personal data. You have the right to
request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal
data.
•
correct inaccurate personal data. You have the
right to request that we correct any inaccurate personal data we maintain about
you, taking into account the nature of the personal
data and the purposes of the processing of the personal data.
•
request the deletion of your personal data. You
have the right to request that we delete any of your personal data.
•
obtain a copy of your personal data. We will
provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that
this is technically feasible.
•
opt out of the processing of your personal data
for the purposes of targeted advertising, the sale of personal data, or
profiling in furtherance of decisions that produce legal or similarly
significant effects concerning you.
In any case, we will
not increase the cost of, or decrease the availability of, a product or
service, based solely on the exercise of any of your rights and unrelated to
the feasibility or the value of a service. However, to the extent permitted by
the law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your
rights
To exercise the rights
described above, you need to submit your request to us by contacting us via the
contact details provided in this document.
For us to respond to
your request, we need to know who you are and which right you wish to exercise.
We will not respond to
any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our
possession actually relate to you. In such cases, we
may request that you provide additional information which is reasonably
necessary to authenticate you and your request.
Making a consumer
request does not require you to create an account with us. However, we may
require you to use your existing account. We will use any personal data
collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it
longer than necessary for purposes of authentication, or using it for unrelated
purposes.
If you are an adult,
you can make a request on behalf of a child under your parental authority.
How and when we are
expected to handle your request
We will respond to your
request without undue delay, but in all cases and at the latest within 45 days
of its receipt. Should we need more time, we will explain to you the reasons
why, and how much more time we need. In this regard, please note that we may
take up to 90 days to fulfill your request.
Should we deny your
request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the
request. It is your right to appeal such decision by submitting a request to us
via the details provided in this document. Within 45 days of receipt of the
appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions. If the appeal is denied, you may contact the Attorney General to
submit a complaint.
We do not charge a fee
to respond to your request, for up to one request per year.
Further information for
Utah consumers
This section of the
document integrates with and supplements the information contained in the rest
of the privacy policy and is provided by the controller running this
Application and, if the case may be, its parent, subsidiaries
and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to
all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are
consumers residing in the State of Utah, according to the “Consumer
Privacy Act" (the “UCPA"),
and, for such consumers, it supersedes any other possibly divergent or
conflicting information contained in the privacy policy.
This part of the
document uses the term “personal data” as defined in the UCPA.
Categories of personal
data processed
In this
section, we summarize the categories of personal data that we've processed and
the purposes thereof. You can read about these activities in detail
in the section titled “Detailed
information on the processing of Persona Data” within this document.
Categories of personal
data we collect
We have collected the
following categories of personal data:
We do not collect
sensitive data.
We will not collect
additional categories of personal data without notifying you.
Why we process your personal
data
To find out why we
process your personal data, you can read the sections titled “Detailed information on
the processing of Personal Data” and “The purposes
of processing” within this document.
How we use the data we
collect: sharing of your personal data with third parties
We do not share nor
disclose your personal data with third parties.
For our purposes, the
word "third party" means "a person other than: the consumer,
controller, or processor; or an affiliate or contractor of the controller or
the processor" as defined by the UCPA.
Sale of your personal
data
We do not sell your
personal data. In case we should decide to, we will inform you beforehand and
will grant your right to opt out of such sale.
For our purposes, the
word "sale", "sell", or "sold" means "the
exchange of personal data for monetary or other valuable consideration by a
controller to a third party" as defined by the UCPA.
Please note that
according to the UCPA, the disclosure of personal data to a processor that
processes personal data on behalf of a controller does not constitute a sale.
In addition, other specific exceptions set forth in the UCPA may apply, such
as, but not limited to, the disclosure of personal data to a third party for
the provision of a product or service requested by you.
Processing of your
personal data for targeted advertising
We do not process your
personal data for targeted advertising. If we decide to do so, we will inform
you beforehand and will grant your right to opt out of the processing of your
personal data for targeted advertising.
For our purposes, the
word "targeted advertising" means "displaying to a consumer an
advertisement that is selected based on personal data obtained or inferred over
time from the consumer's activities across nonaffiliated websites, applications,
or online services to predict consumer preferences or interests" as
defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on
activities within a controller's own websites or online applications or any
affiliated website or online application; advertisements based on the context
of a consumer's current search query, visit to an web site or online
application; advertisements directed to a consumer in response to the
consumer's request for information, product, a service or feedback; or
processing personal data solely to measure or report advertising performance,
reach or frequency.”
Your privacy rights
under the Utah Consumer Privacy Act and how to exercise them
You may exercise
certain rights regarding your data processed by us. In
particular, you have the right to do the following:
•
access personal data. You have the right to
request that we confirm whether or not we are
processing your personal data. You also have the right to access such personal
data.
•
request the deletion of your personal data. You
have the right to request that we delete any of your personal data.
•
obtain a copy of your personal data. We will
provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that
this is technically feasible.
•
opt out of the processing of your personal data
for the purposes of targeted advertising or the sale of personal data.
In any case, we will
not increase the cost of, or decrease the availability of, a product or
service, based solely on the exercise of any of your rights and unrelated to
the feasibility or the value of a service. However, to the extent permitted by
the law, we may offer a different price, rate, level, quality, or selection of
goods or services to you, including offering goods or services for no fee, if
our offer is related to your voluntary participation in a bona fide loyalty,
rewards, premium features, discounts, or club card program.
How to exercise your
rights
To exercise the rights
described above, you need to submit your request to us by contacting us via the
contact details provided in this document.
For us to respond to
your request, we need to know who you are and which right you wish to exercise.
We will not respond to
any request if we are unable to verify your identity using commercially
reasonable efforts and therefore confirm that the personal data in our
possession actually relate to you. In such cases, we
may request that you provide additional information which is reasonably
necessary to authenticate you and your request. We may retain your email
address to respond to your request.
If you are an adult,
you can make a request on behalf of a child under your parental authority.
How and when we are
expected to handle your request
We will respond to your
request without undue delay, but in all cases and at the latest within 45 days
of its receipt. Should we need more time, we will explain to you the reasons
why, and how much more time we need. In this regard, please note that we may
take up to 90 days to fulfill your request.
Should we deny your
request, we will explain to you the reasons behind our denial without undue
delay, but in all cases and at the latest within 45 days of receipt of the
request.
We do not charge a fee
to respond to your request, for up to one request per year.
Additional information
about Data collection and processing
Legal action
The User's Personal
Data may be used for legal purposes by the Owner in Court or in the stages
leading to possible legal action arising from improper use of this Application
or the related Services.
The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities.
Additional information
about User's Personal Data
In addition to the
information contained in this privacy policy, this Application may provide the
User with additional and contextual information concerning particular
Services or the collection and processing of Personal Data upon request.
System logs and
maintenance
For operation and
maintenance purposes, this Application and any third-party services may collect
files that record interaction with this Application (System logs) or use other
Personal Data (such as the IP Address) for this purpose.
Information not
contained in this policy
More details concerning
the collection or processing of Personal Data may be requested from the Owner
at any time. Please see the contact information at the beginning of this
document.
Changes to this privacy
policy
The Owner reserves the
right to make changes to this privacy policy at any time by notifying its Users
on this page and possibly within this Application and/or - as far as
technically and legally feasible - sending a notice to Users via any contact
information available to the Owner. It is strongly recommended to check this
page often, referring to the date of the last modification listed at the
bottom.
Should the changes affect processing activities performed on
the basis of the User’s consent, the Owner
shall collect new consent from the User, where required.