PRIVACY POLICY
Privacy Policy
davvia and its affiliated
companies and subsidiaries (collectively referred to as “Company,” “we,” or “us”) respect your privacy. This Policy describes the ways we collect information from and about you, and what we do with the information, so that you may decide whether or not to provide information to us. By accessing our website, or purchasing our products or services you agree to this Privacy Statement in addition to any other agreements we might have with you. davvia Privacy Statement does not govern the practices of entities that our Company does not own or control, or entities that do not own or control our company or people that our Company does not employ or manage. This Privacy Policy Statement incorporates the Privacy Shield Statement, as is listed below.
Security
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Collection of your Personal Information
The information we collect may include your personal information, such as your name, contact information, IP addresses, product and service selections, and other things that identify you. We collect personal information from you at certain points, including but not limited to the following:
● When we correspond with you as a customer or prospective customer;
● When you visit our website;
● When you register as an end-user of our services and an account is created for you;
● When you contact us for help;
● When you attend our customer conferences or webinars; and
● When the site sends us error reports or application analytics data.
Our Use of your Personal Information
Our Company may use information that we collect about you to:
● Deliver the products and services that you have requested;
● Provide you with customer support;
● Perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
● Communicate with you by e-mail, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
● Develop and display content and advertising tailored to your interests on our site and other websites;
● Verify your eligibility and deliver prizes in connection with promotions, contests, and sweepstakes;
● Enforce our terms and conditions;
● Manage our business;
● Transfer personal information to third parties for any legally permissible purpose at our sole discretion.
Disclosure of your Personal Information to Third Parties
We may share your personal information with third parties in the following ways:
● We may provide your information to our agents, vendors, or service providers who perform functions on our behalf or who help us provide and support our Services. For example, if it is necessary to provide you with something you have requested. Examples of our Vendors and Service Providers include payment processors, hosting services, and content delivery services, such as Salesforce, Stripe, Zendesk, Google, Drip, Mail Chimp, Intercom, Facebook ;
● Third-party contractors may have access to our databases. Usually, these contractors sign a standard confidentiality agreement;
● We may share your data with any parent company, subsidiaries, joint ventures, other entities under common control, or third-party acquirers. We expect these other entities will honor this Privacy Statement;
● We may allow a potential acquirer or merger partner to review our databases, although we would restrict their use and disclosure of this data during the diligence phase;
● As required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to our Company; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our agreements or Company policies; and
● Sometimes, we share your information with our third-party Service Providers,
● We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
● Other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.
Public Information
● We have public blogs on our Website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at admin@avvia.com or click the “unsubscribe” link found at the bottom of every email.
● Social media platforms and widgets. Our Websites include social media features, these features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including but not limited to Facebook, Twitter, Instagram, and Pinterest. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves.
Our Security Measures to Protect your Personal Information
Our Company uses industry-standard technologies when transferring and receiving data exchanged between our Company and other companies to help ensure its security. This site has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. However, “perfect security” does not exist on the Internet. Also, if this website contains links to other sites, our Company is not responsible for the security practices or the content of such sites.
Our Use of Cookies, Web Beacons, Web Analytics Services, and Links
● Cookies are text files we place in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information unless you choose to provide this information to us by, for example, registering at one of our sites. However, once you choose to furnish the site with personal information, this information may be linked to the data stored in the cookie. We use cookies to allow you to log in to your account, and also for us to understand site usage and to improve the content and offerings on our sites. We also may use cookies to offer you products, programs, or services. You have many choices with regard to the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies, please consult the privacy features in your browser.
● Web Beacons. Our Company and third parties may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. These “web beacons” may be used to deliver cookies that conform to our Company’s cookie requirements.
● Web Analytics Services. We use Google Analytics, a service for the marketing analysis of the site provided by Google, Inc. Google Analytics uses cookies to allow us to see how you use our site so we can improve your experience. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy available at http://www.google.com/policies/privacy/. You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.
● We may create links to other websites. We will make a reasonable effort to link only to sites that meet similar standards for maintaining each individual’s right to privacy. However, many other sites that are not associated with or authorized by our Company may have links leading to our site. Our Company cannot control these links and we are not responsible for any content appearing on these sites. Since this website does not control the privacy policies of third parties, you are subject to the privacy practices of that third party. We encourage you to ask questions before you disclose any personal information to others.
● Our Company websites may use third parties to present or serve the advertisements that you may see on its web pages and to conduct research about the advertisements and web usage. This Privacy Statement does not cover any use of information that such third parties may have collected from you or the methods used by the third parties to collect that information.
Our Retention of your Personal Information
We will retain any personal information only for as long as is necessary to fulfill the business purpose it was collected. We will also retain and use your personal information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Your Right to Opt-Out or Unsubscribe from Communication
If you do not want to receive communication from us in the future, please let us know by sending us an e-mail at admin@avvia.com. If you supply us with your postal address on-line you will only receive the information for which you provided us your address.
International Transfers of your Personal Information
Information collected from you may be stored and processed in the United States or any other country in which our Company or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country. European Union or Swiss individuals may refer to the Privacy Shield statement with regard to the transfer of their personal data. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of information that we have collected from you at our site.
Merchants and Partners
The GDPR also applies to the associates and partners of davvia who operate in the EU/EEA (European Union/European Economic Area) or Switzerland and offer goods or services to residents of the EU/EEA or Switzerland. While davvia is performing an action to be compliant with GDPR and to provide its associates and partners with tools to help them comply, each of them is ultimately responsible for ensuring that their business complies with the laws of the jurisdictions in which they operate or have buyers. Using davvia does not guarantee that an associate or partner complies with GDPR.
Merchants and Partners Access to and Updating or Deletion of your Personal Information
The GDPR also gives certain rights to identified or identifiable persons (referred to as data subjects), including davvia associates and partners. These include the right to request at no cost;
● Deletion of personal data
● Correction of their data
● Access to their data
● An export of their data in a portable format
Buyers
The GDPR also gives certain rights to identified or identifiable persons (referred to as data subjects), including buyers visiting stores belonging to davvia. These include the right to request;
● Deletion of personal data
● Correction of their data
● Access to their data
● An export of their data in a portable format
Payment
If you choose a direct payment gateway to complete your purchase, then davvia stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
Changes to our Privacy Statement
Our Company may amend this Privacy Statement at any time by posting a new version. It is your responsibility to review this Privacy Statement periodically as your continued use of this website represents your agreement with the then-current Privacy Statement.
Contacting Us
If you have any questions about this Privacy Statement, the practices or concerns of this site, or feel that the site is not following its said policy, please contact our Privacy Officer at admin@avvia.com.
Privacy Shield Statement davvia complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. This Privacy Statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it, and the notice and choice affected individuals have regarding our use of and their ability to correct that information.
A) Definitions
“Personal Data” means information that
(1) is transferred from the EU/EEA or Switzerland to the United States;
(2) is recorded in any form;
(3) is about, or pertains to a specific individual; and
(4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or that concerns an individual’s health.
B) Principles
davvia may receive Personal Data from its own personnel as well as from its affiliates and other parties located in the EU/EEA. Such information may contain names, addresses, email addresses, and payment information and may be about customers, clients of customers, business partners, consultants, employees, and candidates for employment and includes information recorded on various media as well as electronic data.
Other than its own human resources data, davvia generally does not collect Personal Data directly from individuals. davvia, however, acting as a data processor may receive Personal Data via its customers.
Personal Data Collection Principles:
1. We shall inform an individual of the purpose for which we collect and use their Personal Data and the types of third parties to which our Company discloses or may disclose that Personal Data. Our Company shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to our Company, or as soon as practicable thereafter, and in any event, before our Company uses or discloses the Personal Data for a purpose other than for which it was originally collected. davvia may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
2. Individuals have the opportunity to choose (opt-out) whether their Personal Data is (1) to be disclosed to a non-Agent third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual by contacting our privacy officer via email at admin@avia.com. Agents, technology vendors, and/or contractors of davvia or its affiliates may have access to an individual’s Personal Data on a need-to-know basis for the purpose of performing services on behalf of davvia or providing or enabling elements of the services. All such agents, technology vendors, and contractors who have access to such information are contractually required to keep the information confidential and not use it for any other purpose than to carry out the services they are performing or as otherwise required by law.
3. Accountability for Onward Transfer. Prior to disclosing Personal Data to a third party, we shall notify the individual of such disclosure and allow the individual the choice (opt-out) of such disclosure. We will:
● Limit the data we share with our partners and vendors to only that data we have permission to share.
● Proactively confirm that our partners and vendors understand purpose limitations.
● Ensure partners and vendors will make at least the same level of privacy protection as required by the Privacy Shield principles to comply with the purpose limitation and appropriate protection of that data.
● Transfer such data only for limited and specified purposes as detailed in the privacy policy.
● Ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles.
● Take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with our organization’s obligations under the Principles.
● Upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing.
● davvia requires any third-party agent to notify us in the event that it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield principles.
● Provide a summary or representative copy, of the relevant privacy policy provision of its contract with that agent, to the department upon request.
● Unless we prove that we are not responsible for the event giving rise to the damage. davvia recognizes its responsibility and potential liability for onward transfers.
4. Data Security. We shall take reasonable steps to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Our Company has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. However, our Company cannot guarantee the security of Personal Data on or transmitted via the Internet.
5. Data Integrity and Purpose Limitation. We shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, our Company shall take reasonable steps to ensure that Personal Data is accurate, complete, current, and reliable for its intended use.
6. Access and Recourse. We acknowledge the individual’s right to access their Personal Data. We shall allow an individual access to their Personal Data and allow the individual the opportunity to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals may contact our Privacy Officer via email to request access.
7. Enforcement and Liability. The Federal Trade Commission has jurisdiction over davvia compliance with the Privacy Shield. In compliance with the EU-US Privacy Shield Principles, davvia commits to resolve complaints about privacy and our collection or use of Personal Data. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at contact our Privacy Compliance Officer at admin@avvia.com or by mail at davvia, 1411–5500 Yonge Street, Toronto, ON M2N 7L1, Canada
a. Human Resources Data. davvia would generally not collect human resources data. If there was reason to collect such information and there was a complaint it would be addressed within a timely period. If your complaint is not satisfactorily addressed by davvia, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. davvia agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC. The services of EU DPAs are provided at no cost to you.
b. Independent Recourse — Non-Human Resources Data. davvia has further committed to refer unresolved Privacy Shield complaints to EU data protection authorities (“DPA Panel”) and The Swiss Federal Data Protection and Information Commissioner (“FDPIC”), an alternative dispute resolution provider located in the (the EU, or Switzerland, as applicable). If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit :
EU DPA Contact:
https://ec.europa.eu/info/departments/justice-and-consumers_en
contact Phone number+32 2 299 11 11 (Commission switchboard)
Postal address: Directorate-General for Justice and Consumers European Commission 1049 Bruxelles/Brussel Belgium
FDPIC Contact:
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html
Data Protection and Information Commissioner of Switzerland Tell. +41 58 462 43 95; Fax +41 58 462 99 96
Please note that if your complaint is not resolved through any of the above channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
C) Amendments
This Privacy Statement may be amended from time to time consistent with the requirements of the Shield Frameworks. We will post any revised policy on this website.
D) Information Subject to Other Policies
We are committed to following the Principles for all Personal Data within the scope of the Privacy Shield Frameworks. We are committed to following the Principles for all Personal Data within the scope of the Privacy Shield Frameworks. However, certain information is subject to policies of davvia that may differ in some respects from the general policies set forth in this Privacy Statement.
Privacy Policy of www.bettersilver.it
This Application collects some Personal Data from its Users.
This document contains a section dedicated to Californian consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Owner and Data Controller
Better Silver S.p.A. – P. IVA 00573140241, Via dell’Artigianato, 25 – 36050 Bressanvido – Vicenza – Italia
Owner contact email: amministrazione@bettersilver.it
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; first name; last name; various types of Data; Trackers; Usage Data; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- 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.
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.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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 do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The 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: Contacting the User, Registration and authentication provided directly by this Application, SPAM protection, Analytics, Traffic optimisation and distribution and Displaying content from external platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
Further information about the processing of Personal Data
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:
- 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. Further details are provided in the dedicated section below.
- 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, under certain circumstances, 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, under certain circumstances, 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. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
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 without providing any justification. 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. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
This Application uses Trackers. To learn more, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) 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 honour 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.
Information for Californian consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).
Categories of personal information collected, disclosed or sold
In this section we summarise the categories of personal information that we’ve collected, disclosed or sold 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 information and inferred information.
We will not collect additional categories of personal information without notifying you.
How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorise us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this document.
Sale 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 another business or a third party, for monetary or other valuable consideration”.
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.
Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.
Your California privacy rights and how to exercise them
The right to know and to portability
You have the right to request that we disclose to you:
- the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
- in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
- for sales, the personal information categories purchased by each category of recipient; and
- for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.
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 authorised representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you can authorise 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 minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Information for Users residing in Brazil
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymised personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorised by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
