privacy policy

This Application collects some Personal Data from its Users.

1
Owner and Data Controller

BRIDGERS SAS
149 RUE DU MAINE, 75014 Paris, France
SIREN : 882679749 VAT : FR78882679749 Owner contact email: contact@emelia.io

2
Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

  • Usage Data
  • Trackers
  • Email address
  • Universally unique identifier (UUID)
  • Data communicated while using the service
  • First name
  • Company name
  • Payment info
  • Last name
  • Billing address
  • Purchase history
  • Session duration
  • Scroll-to-page interactions
  • Clicks
  • Country
  • Time zone
  • Device information
  • Mouse movements
  • Interaction events
  • Diagnostic events
  • Page events
  • Custom events
  • Layout details
  • Positional information
  • Number of Users
  • Session statistics
  • Language

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.

Mandatory Data Collection

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 this document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published, or shared through this Application.

3
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 obligations or based on the Users’ consent.

4
The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

  • Tag Management
  • Displaying content from external platforms
  • Hosting and backend infrastructure
  • User database management
  • Handling activities related to productivity
  • Managing contacts and sending messages
  • Handling payments
  • Collection of privacy-related preferences
  • Heat mapping and session recording
  • Analytics
  • Registration and authentication provided directly by this Application
  • Contacting the User

For specific information about the Personal Data used for each purpose, the User may refer to the section Detailed Information on the Processing of Personal Data.

5
Detailed Information on the Processing of Personal Data

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

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics 4 (Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: number of Users, session statistics, Trackers, Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.

Collection of Privacy-Related Preferences

This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

iubenda Privacy Controls and Cookie Solution (iubenda srl)

The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on this Application.

Personal Data processed: Trackers.
Place of processing: Italy – Privacy Policy.

Contacting the User

Contact Form (this Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.

Personal Data processed: company name, email address, first name, last name.

Displaying Content from External Platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google Ireland Limited)

Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers, Usage Data.
Place of processing: Ireland – Privacy Policy.

Handling Activities Related to Productivity

This type of service helps the Owner to manage tasks, collaboration, and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question. These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

Gmail (Google Ireland Limited)

Gmail is a service that manages email communication provided by Google Ireland Limited. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.

Personal Data processed: company name, Data communicated while using the service, email address, first name, Usage Data.
Place of processing: Ireland – Privacy Policy.

Google Sheets (Google Ireland Limited)

Google Sheets is an online spreadsheet and collaboration service provided by Google Ireland Limited.

Personal Data processed: Data communicated while using the service.
Place of processing: Ireland – Privacy Policy.

Notion (Notion Labs, Inc.)

Notion is an online text-editing and collaboration service provided by Notion Labs, Inc.

Personal Data processed: Data communicated while using the service.
Place of processing: United States – Privacy Policy.

Handling Payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer, or other means via external payment service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Payments Europe, Limited)

Stripe is a payment service provided by Stripe Payments Europe, Limited.

Personal Data processed: billing address, email address, first name, last name, payment info, purchase history, Trackers, Usage Data, various types of Data as specified in the privacy policy of the service.
Place of processing: European Union – Privacy Policy.

Heat Mapping and Session Recording

Heat mapping services are used to display the areas of this Application that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior. Some of these services may record sessions and make them available for later visual playback.

Microsoft Clarity (Microsoft Corporation)

Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation. Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

Personal Data processed: clicks, country, custom events, device information, diagnostic events, interaction events, layout details, mouse movements, page events, positional information, scroll-to-page interactions, session duration, time zone, Trackers, Usage Data.
Place of processing: France – Privacy Policy.

Hosting and Backend Infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.

Managing Contacts and Sending Messages

This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information to communicate with the User.

Amazon Simple Email Service (SES) (Amazon Europe)

Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

Personal Data processed: email address.
Place of processing: Luxembourg – Privacy Policy.

Registration and Authentication Provided Directly by this Application

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct Registration (this Application)

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

Personal Data processed: company name, email address, first name, language.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.

User Database Management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

Intercom (Intercom Inc.)

Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within this Application. Intercom Messenger may use Trackers to recognize and track Users behavior.

Personal Data processed: Data communicated while using the service, email address, Trackers, Universally unique identifier (UUID), Usage Data, various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Information on Opting Out of Interest-Based Advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further Information About the Processing of Personal Data

Selling Goods and Services Online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

6
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 fulfill 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.

7
The Rights of Users

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.

8
Additional Information for Users

Further Information for Users in Switzerland

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.

The Rights of Users According to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including the following:

  • Right of access to Personal Data.
  • Right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited).
  • Right to receive their Personal Data and have it transferred to another controller (data portability).
  • Right to ask for incorrect Personal Data to be corrected.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

Further Information for Users in Brazil

This 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.
  • 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 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.
  • 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 international law.
  • When the transfer is necessary to protect your life or physical security or those of a third party.
  • When the transfer is authorized by the ANPD.
  • When the transfer results from a commitment undertaken in an international cooperation agreement.
  • When the transfer is necessary for the execution of a public policy or legal attribution of public service.
  • When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative, or arbitration procedures.

Further Information for 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, commercial information, internet or other electronic network activity information, geolocation data, and inferences drawn from other personal information.

We have collected the following categories of sensitive personal information: payment info.

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 we will 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.

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 Personal Data” within this document.

Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, and inferred information.

We do not collect sensitive data.

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

Why We Process Your Personal Data

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

We won’t process your information for unexpected purposes or for purposes incompatible with the purposes originally disclosed without your consent.

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How We Use the Data We Collect: Sharing of Your Personal Data with Third Parties

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

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

Sale of Your Personal Data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.

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

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

Your Right to Opt Out of the Sale of Your Personal Data and How You Can Exercise It

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

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

Processing of Your Personal Data for Targeted Advertising

For our purposes, the word "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;
  • 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: 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.

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 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 a 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 Personal Data” within this document.

Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, and inferred information.

We do not collect sensitive data.

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

Why We Process Your Personal Data

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

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

How We Use the Data We Collect: Sharing of Your Personal Data with Third Parties

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

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

Sale of Your Personal Data

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

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

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

Your Right to Opt Out of the Sale of Your Personal Data and How You Can Exercise It

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

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

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

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

Processing of Your Personal Data for Targeted Advertising

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 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 abide by such a request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

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 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 Personal Data” within this document.

Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, and inferred information.

We do not collect sensitive data.

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

Why We Process Your Personal Data

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

We won’t process your information for unexpected purposes or for purposes incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How We Use the Data We Collect: Sharing of Your Personal Data with Third Parties

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

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

Sale of Your Personal Data

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

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

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

Your Right to Opt Out of the Sale of Your Personal Data and How You Can Exercise It

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

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

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

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

Processing of Your Personal Data for Targeted Advertising

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 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 abide by such a request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

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 Personal Data” within this document.

Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, and inferred information.

We do not collect sensitive data.

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

Why We Process Your Personal Data

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

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

How We Use the Data We Collect: Sharing of Your Personal Data with Third Parties

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

For our purposes, the word "third party" means "a person 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;
  • 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 abide by such a request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

9
Additional Information for Users

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) 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.

How “Do Not Track” Requests Are Handled

This Application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

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.

10
Definitions and Legal References

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer.

11
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 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 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.

Definitions and Legal References

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal Information

This privacy statement has been prepared based on provisions of multiple legislations. This privacy policy relates solely to this Application, if not stated otherwise within this document.

Last update: August 27, 2024

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