Privacy policy

Data Controller

Studio19 di Giacomo Caporusso, Via Falcone e Borsellino 81 76121 Barletta (BT)

Email address of the Owner: sales.freelifeab@studio19adv.com

Types of Data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: Usage Data; Tracking Tool; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); first name; last name; phone number; Data communicated during the use of the service; responses to questions; user content; message or email content; profile picture; message date; time the message was sent; message sender; various types of Data; Tax Code.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the collection of the Data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from providing such Data, without any consequences on the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies - or other tracking tools - by this Application or the owners of third-party services used by this Application aims to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application.

Methods and location of Data processing

Processing methods

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

Location

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

Retention period

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on the Users' consent.

Purpose of Data Processing

The User's Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), identify any fraudulent or malicious activities, as well as for the following purposes: Platform and hosting services, Payment management, Tag management, Advertising, Displaying content from external platforms, Statistics, Traffic optimization and distribution, Interaction with live chat platforms, Contacting the User, Registration and authentication provided directly by this Application, and Contact management and message sending.

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

Details on the processing of Personal Data

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

• Contact the User

  Contact form (this Application)

  The User, by filling out the contact form with their Data, consents to their use for responding to requests for information, quotes, or any other nature indicated by the form's heading.

  Personal Data processed: Tax Code; various types of Data.

  Category of personal information collected under the CCPA: identifiers.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA

  Mailing list or newsletter (this Application)

  By subscribing to the mailing list or newsletter, the User's email address is automatically added to a contact list to which email messages containing information, including commercial and promotional content, related to this Application may be sent. The User's email address may also be added to this list as a result of registering for this Application or after making a purchase.

  Personal Data processed: Tracking Tools.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA

• Contact management and message sending

  This type of service allows for the management of a database of email contacts, phone contacts, or contacts of any other type, used to communicate with the User.
  These services may also allow for the collection of data related to the date and time the messages are viewed by the User, as well as the User's interaction with them, such as information on clicks on the links included in the messages.

  Klaviyo (Klaviyo Inc.)

  Klaviyo is an email address management and messaging service provided by Klaviyo Inc.

  To use the service provided by Klaviyo, the Owner generally shares information regarding Users (who make purchases), such as contact details and purchase history. For more information regarding the extent of such sharing, check the details below the heading “Personal Data processed”.

  Personal Data processed: Usage data.

  Place of processing: United States – Privacy Policy – Opt out.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • a sharing under the CCPA
  • targeted advertising under the VCDPA, CPA, CTDPA, and UCPA

• Payment management

  Unless otherwise specified, this Application processes all payments by credit card, bank transfer, or other means through external payment service providers. In general, and unless otherwise indicated, Users are requested to provide payment details and personal information directly to such payment service providers.
  This Application is not involved in the collection and processing of such information: it will only receive a notification from the payment service provider regarding the completed payment.

  PayPal (Paypal)

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

  Personal Data processed: Usage data.

  Place of processing: See the privacy policy of Paypal – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CPA, CTDPA, and UCPA

  Google Pay (Google LLC)

  Google Pay is a payment service provided by Google LLC, allowing the User to make online payments using their Google credentials.

  Personal Data processed: Usage data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

• Tag management

  This type of service is functional for the centralized management of tags or scripts used on this Application.
  The use of such services involves the flow of User Data through them and, if applicable, their retention.

  Google Tag Manager (Google LLC)

  Google Tag Manager is a tag management service provided by Google LLC.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under CCPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

• Interaction with live chat platforms

  This type of service allows interaction with live chat platforms managed by third parties, directly from the pages of this Application, in order to contact and be contacted by the support service of this Application.
  In the event that an interaction service with live chat platforms is installed, it is possible that, even if Users do not use the service, it collects Usage Data related to the pages where it is installed. Additionally, live chat conversations may be recorded.

  WhatsApp Business Chat widget (Meta Platforms, Inc.)

  The WhatsApp Business Chat widget is an interaction service with the WhatsApp live chat platform, provided by Meta Platforms, Inc.

  Personal Data processed: surname; message or email content; user content; message date; Data communicated during the use of the service; profile picture; message sender; name; phone number; time the message was sent; answers to questions.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: identifiers; information related to internet or other network activities; audio, electronic, visual, thermal, olfactory, or similar information; information derived from other personal information.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • a sharing under the CCPA
  • targeted advertising under the VCDPA, CPA, CTDPA, and UCPA

• Traffic optimization and distribution

  This type of service allows this Application to distribute its content through servers located in the territory and to optimize its performance.
  The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter communications between this Application and the User's browser.
  Given the distributed nature of this system, it is difficult to determine the locations where content is transferred, which may contain the User's Personal Data.

  Cloudflare (Cloudflare Inc.)

  Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  The integration methods of Cloudflare require that it filters all traffic of this Application, that is, the communications between this Application and the User's browser, also allowing the collection of statistical data on it.

  Personal Data processed: various types of Data as specified by the service's privacy policy.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: identifiers.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA

  Bunny CDN (BunnyWay d.o.o.)

  Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.

  Personal Data processed: Usage data.

  Place of processing: Slovenia – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA

• Advertising

  Some of the services listed below may use Tracking Tools to identify the User, or use behavioral retargeting techniques, that is, display personalized advertisements based on the User's interests and behavior, or measure ad performance. For more information, we suggest checking the privacy policies of the respective services. Generally, such services offer the option to disable this tracking. In addition to any opt-out feature provided by any of the services listed in this document, the User can read more about how to disable interest-based advertising in the section "How to Disable Interest-Based Advertising" in this document.

  Google Ads conversion tracking (Google LLC)

  Google Ads conversion tracking is a statistics service provided by Google LLC that links data from the Google Ads ad network with actions taken within this Application.

  Personal Data processed: Usage Data; Tracking Tools.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

  Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

  Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms Ireland Limited that links data from the Meta ad network with actions taken within this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network.

  Personal Data processed: Usage Data; Tracking Tools.

  Place of processing: Ireland – Privacy Policy – Opt out.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

• Registration and authentication provided directly by this Application

  By registering or authenticating, the User allows this Application to identify them and grant access to dedicated services. Personal Data is collected and stored solely for the purpose of registration or identification. The Data collected is only what is necessary to provide the service requested by the User.

  Direct registration (this Application)

  The User registers by filling out the registration form and directly providing their Personal Data to this Application.

  Personal Data processed: various types of Data.

  Category of personal information collected under the CCPA: identifiers.

• Platform and hosting services

  These services aim to host and operate key components of this Application, making it possible to deliver this Application from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, user registration management, comment and database management, e-commerce, payment processing, etc. The use of such tools involves the collection and processing of Personal Data.
  Some of these services operate through servers located in different geographical locations, making it difficult to determine the exact place where Personal Data is stored.

  Shopify (Shopify Inc.)

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

  Personal Data processed: Usage data.

  Location of processing: Canada – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

• Statistics

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

  Advertising report generation features in Google Analytics (Google LLC)

  Google Analytics on this Application has activated advertising report generation features, which collect additional information from the DoubleClick cookie (web activity) and device advertising IDs (application activity). This allows the Owner to analyze specific Data related to User behaviors and interests (Traffic Data and User interaction Data with ads) and, if enabled, demographic Data (information on age and gender).

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

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

  Location of processing: United States – Privacy Policy – Opt Out.

  Category of personal information collected under the CCPA: identifiers; information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

  Google Analytics 4 (Google LLC)

  Google Analytics is a statistics service provided by Google LLC (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google.
  Google may use Personal Data to contextualize and personalize ads in its advertising network.
  In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult the official Google documentation.

  Personal Data processed: Usage data.

  Location of processing: United States – Privacy Policy – Opt Out.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

• Displaying content from external platforms

  This type of service allows viewing content hosted on external platforms directly from the pages of this Application and interacting with it.
  This type of service may still collect data on web traffic related to the pages where the service is installed, even when users do not use it.

  Google Fonts

  Google Fonts is a font style visualization service managed by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of Data, which allows this Application to integrate such content within its pages.

  Personal Data processed: Usage Data; Tracking Tools.

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

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

  Font Awesome (Fonticons, Inc.)

  Font Awesome is a font style visualization service managed by Fonticons, Inc. that allows this Application to integrate such content within its pages.

  Personal Data processed: Usage Data; Tracking Tools.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: information related to internet or other network activities.

  This type of processing constitutes:

  • a sale under the CCPA, VCDPA, CPA, CTDPA, and UCPA
  • targeted advertising under the CPA, CTDPA, and UCPA

Information on how to disable interest-based advertising

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

Cookie Policy

This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Further information for California consumers

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).

Notice at collection

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

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, internet or other electronic network activity information, audio, electronic, visual, thermal, olfactory, or similar information and inferences drawn from other personal information.

We have collected the following categories of sensitive personal information: message or email content and Tax Code

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

Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it

You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.

We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.

Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and instruct our service providers and contractors to do the same.

To fully exercise your right to limit the use or disclosure of your sensitive personal information, you can contact us at any time using the contact details provided in this document.

For a simplified method, you can also use the privacy choices link provided on this Application.

We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.

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

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 its features (“business purposes”). In such cases, your personal information will be processed in a manner 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 when our rights and interests are threatened or we suffer 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) for which it was collected.

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

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.

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

How we use the information we collect: disclosing your personal information to third parties for a business purpose

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

We disclose your personal information to the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized according to the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration,” as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged,” as defined by the CCPA.
Please note that the exchange of personal information with a service provider under a written contract that meets the requirements set by the CCPA does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

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

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

• the categories of personal information that we collect about you;
• the sources from which the personal information is collected;
• the purposes for which we use your information;
• to whom we disclose such information;
• the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

• the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
• the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by 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 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 that 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 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 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 it to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain 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 them.

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 terms “personal data” (and “sensitive 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 Personal Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, internet information, sensory information and inferred information

With your consent, we collect the following categories of sensitive data: Tax Code

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

Please note that certain exceptions set forth in the VCDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

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

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the term "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the term “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will comply with your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

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

Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications; advertisements based on the context of a consumer's current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.

To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

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

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

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 clearly 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 terms “personal data” (and “sensitive 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 Personal Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, internet information, sensory information and inferred information

With your consent, we collect the following categories of sensitive data: Tax Code

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

Please note that certain exceptions outlined in the CPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

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

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the term "third party" refers to "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.

For our purposes, the term "sale", "sell", or "sold" refers to "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. Additionally, other specific exceptions outlined in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

For our purposes, the term "targeted advertising" refers to "showing a consumer an advertisement that is chosen 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 the 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Universal opt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale of personal data or targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will comply with such requests. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

Your privacy rights under the Colorado Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

• opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
• correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• request the deletion of your personal data. You have the right to request that we delete any of your personal data.
• obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year.

Further information for Connecticut consumers

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to 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 terms “personal data” (and “sensitive 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 Personal Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, internet information, sensory information and inferred information

With your consent, we collect the following categories of sensitive data: Tax Code

You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on this Application. In the event of withdrawal, we will stop processing the relevant data as soon as possible, but no later than 15 days after receiving your withdrawal request.

Please note that certain exceptions set forth in the CTDPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

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

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

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

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.

For our purposes, the term "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

For our purposes, the term "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 websites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet website 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Universal opt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale of personal data or targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will comply with such requests. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

Your privacy rights under the Connecticut Data Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

• access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
• correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• request the deletion of your personal data. You have the right to request that we delete any of your personal data.
• obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
• opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to one request per year.

Further information for Utah consumers

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the terms “personal data” (and “sensitive 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 Personal Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, internet information, sensory information and inferred information

With your consent, we collect the following categories of sensitive data: Tax Code

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

Please note that certain exceptions set forth in the UCPA may apply, such as, but not limited to, when the collection and processing of sensitive data is necessary for the provision of a product or service specifically requested by you.

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

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

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

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

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 a website 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 right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

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.

More information on processing

Legal defense

The User's Personal Data may be used by the Data Controller in legal proceedings or in preparatory stages for potential legal action to defend against misuse of this Application or the related Services by the User.
The User acknowledges that the Data Controller may be required to disclose Data by order of public authorities.

Informative specifications

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

System logs and maintenance

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

Information not contained in this policy

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

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application, as well as, where technically and legally feasible, sending a notification to Users through one of the contact details in its possession. Therefore, please frequently consult this page, referring to the date of the last modification indicated at the bottom.

If the changes involve processing based on consent, the Data Controller will re-obtain the User's consent, if necessary.