Privacy Policy

Privacy Policy of Influenzer

This Application collects some Personal Data from its Users.

 

Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

This document contains a section dedicated to Californian consumers and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

About us

We, Gamestacy Entertainment Private Limited are a gaming company, headquartered in India. Our main business is to create online mobile gaming applications. For more information about us, please see our website at www.gamestacy.com 

 

Policy summary

 

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

 

  • Access to third-party accounts
    • Facebook account access

Permissions: About Me; Birthday; Email; Gender; List of Friends; Photos

  • Advertising
    • AdMob
      • Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
    • Google Ad Manager, Unity Ads, ironSource and Chartboost
      • Personal Data: Cookies; Usage Data
    • Palmup
  • Analytics
    • Google Analytics for Firebase
      • Personal Data: Application opens; Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
    • Google Ads conversion tracking and Google Analytics
      • Personal Data: Cookies; Usage Data
  • Beta Testing
    • TestFlight
      • Personal Data: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service
    • Google Play Beta Testing
      • Personal Data: Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service
  • Contacting the User
    • Contact form
      • Personal Data: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code
    • Mailing list or newsletter
      • Personal Data: email address; first name
  • Content commenting
    • Comment system managed directly
      • Personal Data: username
  • Content performance and features testing (A/B testing)
    • Firebase Remote Config
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Data transfer outside the EU
    • Data transfer abroad based on standard contractual clauses
      • Personal Data: various types of Data
  • Device permissions for Personal Data access
    • Device permissions for Personal Data access
      • Personal Data: Social media accounts permission; Storage permission
  • Handling payments
    • Apple Pay and Google Pay
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Heat mapping and session recording
    • Smartlook
      • Personal Data: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service
  • Hosting and backend infrastructure
    • Vuforia
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Infrastructure monitoring
    • Crashlytics
      • Personal Data: Crash information; device information; Universally unique identifier (UUID)
  • Location-based interactions
    • Non-continuous geolocation
      • Personal Data: geographic position
  • Platform services and hosting
    • Google Play Store and Apple App Store
      • Personal Data: Usage Data
    • WordPress.com
      • Personal Data: various types of Data as specified in the privacy policy of the service
  • Registration and authentication
    • Facebook Authentication and Google OAuth
      • Personal Data: various types of Data as specified in the privacy policy of the service
    • Sign in with Apple
      • Personal Data: email address; first name; last name; phone number; User ID
  • Registration and authentication provided directly by this Application
    • Direct registration
      • Personal Data: email address; gender; username
  • Remarketing and behavioral targeting
    • Facebook Remarketing, Google Ads Remarketing and Google Ad Manager Audience Extension
      • Personal Data: Cookies; Usage Data
    • Facebook Custom Audience
      • Personal Data: Cookies; email address
  • Social features
    • Firebase Dynamic Links
      • Personal Data: various types of Data as specified in the privacy policy of the service
    • Beamable Inc and GetSocial

 

Further information about 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.

 

  • Push notifications based on the User’s geographic location

This Application may use the User’s geographic location to send push notifications for 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 changing those settings for 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.

 

  • Push notifications for direct marketing

This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).

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 changing those settings for this Application 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.

Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

 

  • The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

 

  • Unique device identification

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

 

  • User identification via a universally unique identifier (UUID)

This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

 

  • Analysis and predictions based on the User’s Data (“profiling”)

 We may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows us to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

 

  • Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Us, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

      • to enable or otherwise improve the decision-making process;
      • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
      • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
      • to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

 

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

      • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
      • challenge a decision by asking us to reconsider it or take a new decision on a different basis;
      • request and obtain from us human intervention on such processing.

To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

 

Contact information

  • Owner and Data Controller

GAMESTACY ENTERTAINMENT PRIVATE LIMITED,
712 Managun Mastero, Plot Number F21A, Sector 50 Noida, 201301

 Our contact email: notifyus@gamestacy.com

 

Full policy

 

Owner and Data Controller 

GAMESTACY ENTERTAINMENT PRIVATE LIMITED,
712 Managun Mastero, Plot Number F21A, Sector 50 Noida, 201301

Ourcontact email: notifyus@gamestacy.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; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; email address; Data communicated while using the service; first name; last name; gender; date of birth; username; country; app information; device logs; phone number; VAT Number; company name; profession; address; fax number; state; county; ZIP/Postal code; various types of Data; city; Tax ID; field of activity; User ID; number of employees; website; Storage permission; Social media accounts permission; Universally unique identifier (UUID); Crash information; geographic position. 

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  voluntarily provided by the User, or, in case of Usage Data, collected automatically when using this Application.

Voluntary data provided by the User consists of, but is not limited to, the contact details the User provides in order to register an account with us to begin playing games, to subscribe to news and updates about games marketing from us, and/or to send messages with questions and feedback to us. The User will be informed of what personal information is required and about the reasons why they need to provide it before we start collecting any personal data from the User. The personal information that the User is asked to provide, and the reasons why they are asked to provide it, will be made clear to the User at the time when such information is requested from them.


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  us.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to  us.

 

Mode and place of processing the Data

Methods of processing

We take 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 us, 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 us. The updated list of these parties may be requested from the us at any time.

Legal basis of processing

We may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations we may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which we are subjected;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in  us;
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case,  we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. 

Place

The Data is processed at our 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.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or 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  usto safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

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

We 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,  we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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

 

The purposes of processing

The Data concerning the User is collected to allow  us to provide  our Service, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Advertising, Analytics, Beta Testing, Contacting the User, Content performance and features testing (A/B testing), Content commenting, Device permissions for Personal Data access, Handling payments, Heat mapping and session recording, Hosting and backend infrastructure, Access to third-party accounts, Data transfer outside the EU, Infrastructure monitoring, Location-based interactions, Platform services and hosting, Registration and authentication, Registration and authentication provided directly by this Application, Remarketing and behavioral targeting and Social features. 

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.

About Me

Provides access to the ‘About Me’ section of the profile.

Birthday

Provides access to the birthday.

Email

Provides access to the User’s primary email address.

Gender

Provides access to the User’s gender.

List of Friends

Provides access to the User’s list of friends that also use said app.

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

 

Device permissions for Personal Data access

Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact  usfor support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Social media accounts permission

Used for accessing the User’s social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

 

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.

Facebook account access (Facebook, Inc.)

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

Permissions asked: About Me; Birthday; Email; Gender; List of Friends; Photos. 

Place of processing: United States – Privacy Policy. Privacy Shield participant. 

Category of personal data collected according to CCPA: identifiers; california Consumer Records Statute information; biometric information; internet information; sensorial information. 

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.
In addition to any opt-out feature offered 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.

AdMob 

AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.
In order to understand Google’s use of Data, consult Google’s partner policy.

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

Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy Policy. Privacy Shield participant. 

Category of personal data collected according to CCPA: identifiers; internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Ad Manager 

Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, that allows  us to run advertising campaigns in conjunction with external advertising networks that we, unless otherwise specified in this document, have 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; Ireland – Privacy Policy. Privacy Shield participant. 

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Unity Ads (Unity Technologies ApS)

Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data processed: Cookies; Usage Data. 

Place of processing: Denmark – Privacy Policy

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

ironSource (ironSource Ltd.)

ironSource is an advertising service provided by ironSource Ltd.

Personal Data processed: Cookies; Usage Data. 

Place of processing: Israel – Privacy Policy

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Chartboost (Chartboost, Inc.)

Chartboost is an advertising service provided by Chartboost Inc.

Personal Data processed: Cookies; Usage Data. 

Place of processing: United States – Privacy Policy

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Palmup 

Palmup operates a platform that enables advertisers and market researchers (collectively referred to as “campaign partners”) to reach the users of mobile apps, mobile app users to be compensated for their attention to campaigns, and mobile app publishers to receive revenue based on their users’ interactions with campaigns displayed in their applications.

Privacy Policy: https://docs.palmup.io/legal-section/privacy-policy
Terms of use: https://docs.palmup.io/legal-section/legal 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Beta Testing

This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User’s use of this Application in a personally identifiable form.

TestFlight (Apple Inc.)

TestFlight is a beta testing service provided by Apple Inc.

Personal Data processed: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username; various types of Data as specified in the privacy policy of the service. 

Place of processing: United States – Privacy Policy

Category of personal data collected according to CCPA: identifiers; biometric information; internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Play Beta Testing 

Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service. 

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

Category of personal data collected according to CCPA: identifiers; biometric information; internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

 

Contacting the User

Contact form (this Application)

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

Personal Data processed: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code. 

Category of personal data collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information; inferred information. 

Mailing list or newsletter (this Application)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data processed: email address; first name. 

Category of personal data collected according to CCPA: identifiers. 

Content performance and features testing (A/B testing)

The services contained in this section allow  usto track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.

Firebase Remote Config 

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

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

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

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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\ us, 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.

Comment system managed directly (this Application)

This Application has its own internal content comment system.

Personal Data processed: username. 

Category of personal data collected according to CCPA: identifiers. 

Data transfer outside the EU

We are allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with us to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (this Application)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by  usaccording to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact  usthrough the contact details provided in the present document.

Personal Data processed: various types of Data. 

Category of personal data collected according to CCPA: internet information. 

Heat mapping and session recording

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

Smartlook (Smartsupp.com, s.r.o.)

Smartlook is a session recording and heat mapping service provided by Smartsupp.com, s.r.o.

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

Place of processing: Czech Republic – Privacy Policy

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

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 data collected according to CCPA: internet information. 

Google Pay 

Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from,, which allows users to make online payments using their Google credentials.

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

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

Category of personal data collected according to CCPA: internet information. 

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.

Vuforia (PTC, Inc)

Vuforia is a hosting and backend service provided by PTC, 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 data collected according to CCPA: internet information. 

Infrastructure monitoring

This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

Crashlytics 

Crashlytics is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from.

Personal Data processed: Crash information; device information; Universally unique identifier (UUID). 

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

Category of personal data collected according to CCPA: identifiers; internet information. 

 Location-based interactions

Non-continuous geolocation (this Application)

This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
The geographic location of the User is determined in a manner that isn’t continuous, either at the specific request of the User or when the User doesn’t point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data processed: geographic position. 

Category of personal data collected according to CCPA: geolocation data. 

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Facebook Authentication 

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, and is connected to the Facebook social network.

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

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

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Sign in with Apple (Apple Inc.)

Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account – therefore shielding their actual email address from  us.

Personal Data processed: email address; first name; last name; phone number; User ID. 

Place of processing: United States – Privacy Policy

Category of personal data collected according to CCPA: identifiers. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google OAuth 

Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, and is connected to the Google network.

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

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

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Registration and authentication provided directly by this Application

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

Direct registration (this Application)

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

Personal Data processed: email address; gender; username. 

Category of personal data collected according to CCPA: identifiers; biometric information. 

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.

Facebook Remarketing 

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, that connects the activity of this Application with the Facebook advertising network.

Personal Data processed: Cookies; Usage Data. 

Place of processing: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant. 

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Ads Remarketing 

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, 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: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant. 

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Facebook Custom Audience 

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, 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 PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant. 

Category of personal data collected according to CCPA: identifiers; internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Ad Manager Audience Extension 

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, 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 PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant. 

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Social features

Firebase Dynamic Links 

Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs  us about the details of the User journey to and within this Application.

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

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

Category of personal data collected according to CCPA: internet information. 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Beamable Inc 

Beamable provides social, commerce, and content management features.

Privacy Policy: https://www.beamable.com/privacy

Terms of Use: https://www.beamable.com/tos 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

GetSocial 

Privacy Policy: https://www.getsocial.im/legal/#privacy-policy
Terms of Use: https://www.getsocial.im/legal/#terms-and-conditions 

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Further information about 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.

  • Push notifications based on the User’s geographic location

This Application may use the User’s geographic location to send push notifications for 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 changing those settings for 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.

  • Push notifications for direct marketing

This Application may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by this Application).

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 changing those settings for this Application 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.

Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

  • The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

  • Unique device identification

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

  • User identification via a universally unique identifier (UUID)

This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

  • Analysis and predictions based on the User’s Data (“profiling”)

 We may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows us to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

  • Automated decision-making

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and us, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking  usto reconsider it or take a new decision on a different basis;
  • request and obtain from  ushuman intervention on such processing.

To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

The rights of Users

Users may exercise certain rights regarding their Data processed by us.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with us to find out which rights apply to them.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case,  wewill not process their Data for any purpose other than storing it. 
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from us.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, Users may object to such processing by providing a ground related to their particular situation to justify the objection. 

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether  we are processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. 

How to exercise these rights

Any requests to exercise User rights can be directed to  usthrough the contact details provided in this document. These requests can be exercised free of charge and will be addressed by  usas early as possible and always within one month.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Owner or an Entity based within the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows the Owner or an Entity to monitor such Users’ behavior taking place in the EU.

Cookie Policy

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

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by  usin Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that we may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from  us at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

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

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, We shall collect new consent from the User, where required.

Information for Californian consumers

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

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

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

Categories of personal information collected, disclosed or sold

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

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, california Consumer Records Statute information, commercial information, biometric information, internet information, geolocation data, sensorial information, employment related information and inferred information.

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

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

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

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

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

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

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

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

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

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

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

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

  • the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
  • in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose: 
    • for sales, the personal information categories purchased by each category of recipient; and 
    • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

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

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

The right to request the deletion of your personal information

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

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

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

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

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an 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.

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 minor under your parental authority.

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

How and when we are expected to handle your request

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

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

Our disclosure(s) will cover the preceding 12 month period.

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

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

Information for Users residing in Brazil

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

The grounds on which we process your personal information

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

  • your consent to the relevant processing activities;
  • compliance with a legal or regulatory obligation that lies with us;
  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on 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.

 

Definitions and legal references 

Personal Data (or Data)

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

Usage Data

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

User

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

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

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

Data Controller (or Owner)

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

This Application

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

Service

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

European Union (or EU) 

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

Cookies

Small sets of data stored in the User’s device.

 


 

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

 

Updates to this Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform the User, consistent with the significance of the changes we make.  We will obtain the User’s consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

Users can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the bottom of this Privacy Policy.

Latest update: September 16, 2020

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