Privacy policy

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Privacy Policy of Product Marketing Alliance

This Application collects some Personal Data from its Users.
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Policy summary

  Access to third-party accounts
     Facebook account access
     Permissions: Contact email

     Twitter account access, Stripe account access, Google Drive account access and Dropbox account access
     Personal Data: various types of Data as specified in the privacy policy of the service


  •   Advertising 
         Direct Email Marketing (DEM)
         Personal Data: first name

         Quora Lookalike Audience, Google Ads Similar audiences, Google Ad Manager and Facebook Lookalike Audience
         Personal Data: Cookies; Usage Data

         Quora List Match Audience
         Personal Data: Cookies; email address; Usage Data

         Facebook Audience Network
         Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

         Sharethrough and Salesforce
         Personal Data: Trackers; Usage Data


      Analytics
        Facebook Ads conversion tracking (Facebook pixel), Google Analytics, Google Ads conversion tracking, Heap Analytics, Google Analytics with
         anonymized IP, Hotjar Form

        Analysis & Conversion Funnels, HubSpot Analytics, LinkedIn conversion tracking, Quora Conversion Pixel, Salesforce Analytics Cloud and
        Twitter Ads conversion tracking
        Personal Data: Cookies; Usage Data

        Facebook Analytics for Apps
        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

        Google Analytics Advertising Reporting Features
        Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the
        privacy policy of the service

       
    Google Analytics Demographics and Interests reports


  •    Content Commenting
         
    Disqus     
         Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service


      Displaying content from external platforms
     
       Google Fonts
        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

        Wistia widget and YouTube video widget
       Personal Data: Cookies; Usage Data

        Gravatar
       Personal Data: email address; Usage Data


      Handling payments
       
    PayPal and Stripe   
        Personal Data: various types of Data as specified in the privacy policy of the service


      Heat mapping and session recording
        Hotjar Heat Maps & Recordings   
        Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service


      Hosting and backend infrastructure
         
    DigitalOcean
         Personal Data: various types of Data as specified in the privacy policy of the service


      Interaction with external social networks and platforms
     
       LinkedIn button and social widgets, Twitter Tweet button and social widgets and Facebook Like button and social widgets
         Personal Data: Cookies; Usage Data


      Managing contacts and sending messages
         ConvertKit
         Personal Data: Cookies; email address; first name; Usage Data

         Drip and Mailchimp
         Personal Data: email address

      Managing data collection and online surveys 
         Typeform and SurveyMonkey
         Personal Data: email address

      Remarketing and behavioral targeting
         Twitter Remarketing, LinkedIn Website Retargeting, Google Ads Remarketing, AdRoll, Facebook Remarketing and Google Ad Manager
           Audience  Extension
         Personal Data: Cookies; Usage Data

         Twitter Tailored Audiences and Facebook Custom Audience
         Personal Data: Cookies; email address

      Tag management
         Segment
         Personal Data: Cookies; Usage Data
         Google Tag Manager
         Personal Data: Usage Data

      User database management
         ActiveCampaign
         Personal Data: Cookies; email address; various types of Data as specified in the privacy policy of the service

         HubSpot CRM
         Personal Data: email address; phone number; various types of Data as specified in the privacy policy of the service

         HubSpot Lead Management
         Personal Data: various types of Data as specified in the privacy policy of the service

        Intercom
        Personal Data: Cookies; email address; Usage Data; various types of Data as specified in the privacy policy of the service

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    Information on opting out of interest-based advertising

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

    Further information about the processing of Personal Data

      Push notification  
    This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. 

    Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    Contact information

      Owner and Data Controller
    Product Marketing Alliance
    147 De Beauvoir Road
    London
    N1 4DL Owner contact email: hello@productmarketingalliance.com


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    FULL POLICY

    Owner and Data Controller

    Product Marketing Alliance
    147 De Beauvoir Road
    London
    N1 4DL

     

    Owner contact email: hello@productmarketingalliance.com

    Types of Data collected

    Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); address; phone number.

     

    Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
    Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
    Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
    Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
    Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

     

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

    Mode and place of processing the Data

    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.

    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.

    Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

    The purposes of processing

    The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Access to third-party accounts, Advertising, Analytics, Content commenting, Displaying content from external platforms, Handling payments, Heat mapping and session recording, Hosting and backend infrastructure, Interaction with external social networks and platforms, Managing data collection and online surveys, Remarketing and behavioral targeting, Tag Management and User database management.

     

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

    Facebook permissions asked by this Application

    This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.

     

    For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

     

    The permissions asked are the following:

    Basic information

    By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

    Contact email

    Access the User's contact email address.


    Detailed information on the processing of Personal Data

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

     
    • Access to third-party accounts

      This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
      These services are not activated automatically, but require explicit authorization by the User.

      Twitter account access (X Corp.)

      This service allows this Application to connect with the User's account on the Twitter social network, provided by Twitter, Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, CPA, CTDPA and UCPA

      Stripe account access (Stripe Inc)

      This service allows this Application to connect with the User's account on Stripe, provided by Stripe, Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Drive account access (Google Ireland Limited)

      This service allows this Application to connect with the User's account on Google Drive, provided by Google Ireland Limited.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: Ireland – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook account access (this Application)

      This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

      Permissions asked: Contact email.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

       
      • a sale according to the CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA

      Dropbox account access (Dropbox, Inc.)

      This service allows this Application to connect with the User's account on Dropbox, provided by Dropbox, Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • Advertising

      This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
      This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
      Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
      Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

      Direct Email Marketing (DEM) (this Application)

      This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application.

      Personal Data processed: first name.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

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

      Quora Lookalike Audience (Quora, Inc.)

      Quora Lookalike Audience is an advertising and behavioral targeting service provided by Quora, Inc. that uses Data collected through the Quora's pixel in order to display ads to Users with similar behavior to Users who are already in an Audience list on the base of their past use of this Application.

       

      On the base of these Data, personalized ads will be shown to Users suggested by Quora Lookalike Audience.

       

      Users can opt out of Quora's use of cookies for ads personalization by visiting this opt-out page. Quora may still show Users contextualized ads relevant to the content they are viewing.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Quora List Match Audience (Quora, Inc.)

      Quora List Match Audience is an advertising and behavioral targeting service provided by Quora, Inc. that allows the Owner to provide a list of email addresses of existing Users and to then match them with existing Users on the Quora Platform so that they can be targeted with personalized ads.

       

      Users can opt out of receiving personalized ads by contacting Quora support via this page. Quora may still show Users contextualized ads relevant to the content they are viewing.

      Personal Data processed: Cookies; email address; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Ads Similar audiences (Google LLC)

      Similar audiences is an advertising and behavioral targeting service provided by Google LLC that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Application.
      On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.

       

      Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.

       

      In order to understand Google's use of Data, consult Google's partner policy.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Ad Manager (Google LLC)

      Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
      This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.  

       

      Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook Lookalike Audience (Facebook, Inc.)

      Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Application or engagement with relevant content across the Facebook apps and services.
      On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

       

      Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook Audience Network (Facebook, Inc.)

      Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

       

      This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

       

      Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

      Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Sharethrough (Sharethrough, Inc)

      Sharethrough is an advertising service provided by Sharethrough, Inc.

      Personal Data processed: Trackers; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Salesforce (Salesforce.com, Inc.)

      Salesforce is an advertising service provided by Salesforce.com, Inc.

      Personal Data processed: Trackers; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • a sharing according to the CCPA
      • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
    • 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.

      Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

      Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook Analytics for Apps (Facebook, Inc.)

      Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

      Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Analytics (Google LLC)

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

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

      Google Ads conversion tracking

      Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Application.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Analytics Advertising Reporting Features (Google LLC)

      Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

       

      Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

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

       

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

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Analytics Demographics and Interests reports (Google LLC)

      Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).

       

      Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

      Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

       

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

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Heap Analytics (Heap Inc.)

      Heap Analytics is an analytics service provided by Heap Inc.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Analytics with anonymized IP (Google LLC)

      Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
      Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
      This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

      Hotjar is an analytics service provided by Hotjar Ltd.
      Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: Malta – Privacy Policy – Opt Out.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      HubSpot Analytics (HubSpot, Inc.)

      HubSpot Analytics is an analytics service provided by HubSpot, Inc.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      LinkedIn conversion tracking (LinkedIn Corporation)

      LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Quora Conversion Pixel (Quora, Inc.)

      Quora Conversion Pixel is an analytics service provided by Quora, Inc. that connects data from the Quora Platform with actions performed on this Application.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Salesforce Analytics Cloud (Salesforce.com, inc.)

      Salesforce Analytics Cloud is an analytics service provided by salesforce.com, inc.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Twitter Ads conversion tracking (X Corp.)

      Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Application.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • Content commenting

      Content commenting services allow Users to make and publish their comments on the contents of this Application.
      Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
      If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

      Disqus (Disqus)

      Disqus is a content commenting service provided by Big Heads Labs Inc.

      Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, CPA and CTDPA
    • Displaying content from external platforms

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

      Google Fonts (Google LLC)

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

      Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Wistia widget (Wistia, Inc.)

      Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate content of this kind on its pages.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      YouTube video widget (Google Ireland Limited)

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

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: Ireland – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Gravatar (Automattic Inc.)

      Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
      Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.

      Personal Data processed: email address; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • 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.

      PayPal (PayPal Inc.)

      PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CPA, CTDPA and UCPA

      Stripe (Stripe Inc)

      Stripe is a payment service provided by Stripe Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • Heat mapping and session recording

      Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. 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.

      Hotjar Heat Maps & Recordings (Hotjar Ltd.)

      Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
      Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

      Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: Malta – Privacy Policy – Opt Out.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • 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.

      DigitalOcean (DigitalOcean Inc.)

      DigitalOcean is a hosting service provided by DigitalOcean Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United Kingdom – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • Interaction with data collection platforms and other third parties

      This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
      If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

      ConvertKit widget (ConvertKit LLC)

      The ConvertKit widget is a service for interacting with the ConvertKit email address management and message sending service provided by ConvertKit LLC.

      Personal Data processed: Cookies; email address; first name; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Mailchimp widget (The Rocket Science Group LLC)

      The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.

      Personal Data processed: email address.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

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

      Typeform widget (TYPEFORM S.L)

      The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.

      Personal Data processed: address; email address.

       

      Place of processing: Spain – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • a sharing according to the CCPA
      • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
    • Interaction with external social networks and platforms

      This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
      The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
      This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
      It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

      LinkedIn button and social widgets (LinkedIn Corporation)

      The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Twitter Tweet button and social widgets (X Corp.)

      The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA and VCDPA

      Facebook Like button and social widgets (Facebook, Inc.)

      The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
    • Managing contacts and sending messages

      This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
      These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

      ConvertKit (ConvertKit LLC)

      ConvertKit is an email address management and message sending service provided by ConvertKit LLC.

      Personal Data processed: Cookies; email address; first name; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Drip (Avenue 81, Inc.)

      Drip is an email address management and message sending service provided by Avenue 81, Inc.

      Personal Data processed: email address.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

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

      Mailchimp (The Rocket Science Group LLC)

      Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

      Personal Data processed: email address.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • a sharing according to the CCPA
      • targeted advertising according to the VCDPA
    • Managing data collection and online surveys

      This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
      The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

       

      These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

      Typeform (TYPEFORM S.L)

      Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

      Personal Data processed: email address.

       

      Place of processing: Spain – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

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

      SurveyMonkey (SurveyMonkey Europe UC)

      SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Europe UC.

      Personal Data processed: email address.

       

      Place of processing: European Union – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • Remarketing and behavioral targeting

      This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
      This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
      Some services offer a remarketing option based on email address lists.
      In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

       

      Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

      Twitter Remarketing (X Corp.)

      Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Twitter Tailored Audiences (X Corp.)

      Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of this Application with the Twitter advertising network.

       

      Users can opt out from interest-based ads by going to: Personalization and Data.

      Personal Data processed: Cookies; email address.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      LinkedIn Website Retargeting (LinkedIn Corporation)

      LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Ads Remarketing (Google Ireland Limited)

      Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

       

      Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      AdRoll (AdRoll, Inc.)

      AdRoll is an advertising service provided by AdRoll, Inc.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook Custom Audience (Facebook, Inc.)

      Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

       

      Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

      Personal Data processed: Cookies; email address.

       

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

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      Facebook Remarketing (Facebook, Inc.)

      Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      Google Ad Manager Audience Extension (Google LLC)

      Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.

      Personal Data processed: Cookies; Usage Data.

       

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

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • a sharing according to the CCPA
      • targeted advertising according to the VCDPA, CPA, CTDPA and UCPA
    • 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.

      Segment (Segment Inc.)

      Segment is a tag management service provided by Segment.io, Inc.

      Personal Data processed: Cookies; Usage Data.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      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.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    • 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.

      ActiveCampaign (ActiveCampaign, Inc.)

      ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

      Personal Data processed: Cookies; email address; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      HubSpot CRM (HubSpot, Inc.)

      HubSpot CRM is a User database management service provided by HubSpot, Inc.

      Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

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

      HubSpot Lead Management (HubSpot, Inc.)

      HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

      Personal Data processed: various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: internet or other electronic network activity information.

       

      This processing constitutes:

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

      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.

      Personal Data processed: Cookies; email address; Usage Data; various types of Data as specified in the privacy policy of the service.

       

      Place of processing: United States – Privacy Policy.

       

      Category of personal information collected according to the CCPA: identifiers; internet or other electronic network activity information.

       

      This processing constitutes:

       
      • a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
      • targeted advertising according to the CPA, CTDPA and UCPA
    Empty space, drag to resize

    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

    • Push notifications

      This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

       

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

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

    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.

    Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

     

    Therefore:

     
    • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
    • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
     

    The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

    Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

    The rights of Users based on the General Data Protection Regulation (GDPR)

    Users may exercise certain rights regarding their Data processed by the Owner.

     

    In particular, Users have the right to do the following, to the extent permitted by law:

     
    • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
    • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
    • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
    • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
    • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
    • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
    • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
     

    Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

    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.

    Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.


    Further information for Users in Brazil

    This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
    This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
    This part of the document uses the term “personal information“ as it is defined in the LGPD.

    The grounds on which we process your personal information

    We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

    • your consent to the relevant processing activities;
    • compliance with a legal or regulatory obligation that lies with us;
    • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
    • studies conducted by research entities, preferably carried out on anonymized personal information;
    • the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
    • the exercising of our rights in judicial, administrative or arbitration procedures;
    • protection or physical safety of yourself or a third party;
    • the protection of health – in procedures carried out by health entities or professionals;
    • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
    • credit protection.


     

    To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

    Categories of personal information processed

    To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

    Why we process your personal information

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

    Your Brazilian privacy rights, how to file a request and our response to your requests

    Your Brazilian privacy rights

    You have the right to:

    • obtain confirmation of the existence of processing activities on your personal information;
    • access to your personal information;
    • have incomplete, inaccurate or outdated personal information rectified;
    • obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
    • obtain information on the possibility to provide or deny your consent and the consequences thereof;
    • obtain information about the third parties with whom we share your personal information;
    • obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
    • obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
    • revoke your consent at any time;
    • lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
    • oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
    • request clear and adequate information regarding the criteria and procedures used for an automated decision; and
    • request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.


     

    You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

    How to file your request

    You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

    How and when we will respond to your request

    We will strive to promptly respond to your requests.
    In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

     

    In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
    You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
    In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

     

    In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

    Transfer of personal information outside of Brazil permitted by the law

    We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

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


    Futher information for California consumers

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

     

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

     

    This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).

    Notice at collection

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

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

    Information we collect: the categories of personal information we collect

    We have collected the following categories of personal information about you: identifiers and internet or other electronic network activity information.

     

    We do not collect sensitive personal information.

     

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

    What are the purposes for which we use your personal information?

    We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

     

    We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

     

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

    How long do we keep your personal information?

    Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

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

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

     

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

     

    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: disclosing of your personal information with third parties for a business purpose

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

     

    We disclose your personal information 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.

    Sale or sharing of your personal information

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

     

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

     

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

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

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

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

     

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

     

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

     

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

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

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

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

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

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

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

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

     

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

    The right to request the deletion of your personal information

    You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

     

    If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

    The right to correct inaccurate personal information

    You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

    The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

    You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

    The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

    We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

     

    However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

     

    To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

    How to exercise your rights

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

     

    For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

     
    • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
    • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
     

    We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

     

    Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

     

    If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

     

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

     

    You can submit a maximum number of 2 requests over a period of 12 months.

    How and when we are expected to handle your request

    We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

     

    We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

     

    Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

     

    Should we deny your request, we will explain you the reasons behind our denial.

     

    We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

    Further information for Virginia consumers

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

     

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

     

    This part of the document uses the term “personal data” as defined in the VCDPA.

    Categories of personal data processed

    In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

    Categories of personal data we collect

    We have collected the following categories of personal data: identifiers and internet 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; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.

     

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

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

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

     

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

    Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

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

     
    • access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
    • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
    • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
    • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
    • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
    • non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

    How to exercise your rights

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

     

    For us to respond to your request, we need to know who you are.

     

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

     

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

     

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

    How and when we are expected to handle your request

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

     

    Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

     

    We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

    Further information for Colorado consumers

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

     

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

     

    This part of the document uses the term “personal data” as defined in the CPA.

    Categories of personal data processed

    In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

    Categories of personal data we collect

    We have collected the following categories of personal data: identifiers and internet 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 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 the 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 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.

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

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

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

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

    How to exercise your rights

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

     

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

     

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

     

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

     

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

    How and when we are expected to handle your request

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

     

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

     

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

    Further information for Connecticut consumers

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

     

    This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

     

    This part of the document uses the term “personal data” as defined in the CTDPA.

    Categories of personal data processed

    In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

    Categories of personal data we collect

    We have collected the following categories of personal data: identifiers and internet 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 web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.

    Your 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 the 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 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.

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

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

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

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

    How to exercise your rights

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

     

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

     

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

     

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

     

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

    How and when we are expected to handle your request

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

     

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

     

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