Data Controller

Sunbasket s.r.l. – Via G. Rossa, 5, 43058 Chiozzola (PR), Italy
Email address of the Data Controller: sun@sunbasket.it
Our website address is: https://www.sunbasket.it.

Types of Data collected

Among the Personal Data collected by this Application, independently or through third parties, there are: Usage data; Data communicated during use of the service; language.

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

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


Method and place of processing of the collected data

Treatment methods

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

Place

The Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

Retention period

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

Purpose of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Creation and management of this Application.

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


Details on the processing of Personal Data

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

Creation and management of this Application

The main components of this Application are created and managed directly by the Owner using the software mentioned below.

WordPress (self-hosted) (this Application)

This Application is developed and managed by the Data Controller through a CMS (Content Management System) software called WordPress.

Personal Data processed: Data communicated during the use of the service; Usage Data; tongue.

Category of Personal Information Collected Under the CCPA: Information about your activities on the Internet or other networks; Information Derived from Other Personal Information.

This type of processing constitutes:

  • a sale under the VCDPA, CPA, CTDPA and UCPA
  • a share under the CCPA
  • targeted advertising under the VCDPA, CPA, CTDPA, and UCPA
Spam & Bot Protection

This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, in order to filter it from unwanted traffic parts, messages and content recognized as SPAM or protect it from malicious bot activity.

Google reCAPTCHA

Google reCAPTCHA is a SPAM protection service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller handles the processing of Data.
The use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use .

Personal Data processed: clicks; Usage Data; keypress events; events related to motion sensors; touch events; mouse movements; position relative to the scroll; answers to questions; Tracking Tools.

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

Category of Personal Information Collected Under the CCPA: Information about your activities on the Internet or other networks; Information Derived from Other Personal Information.

Spam & Bot Protection

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with it. These services are often referred to as widgets, which are small elements placed on a website or application. They provide specific information or perform a particular function and often allow interaction with the user.
This type of service may still collect data about web traffic related to the pages where the service is installed, even when users are not using it.

Gravatar

Gravatar is an image viewing service operated by Automattic Inc. which allows Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Data Controller manages the processing of Data, to integrate such content within its pages.
Please note that if Gravatar images are used for commenting systems, the commenter’s email address (or parts of it) may be sent to Gravatar, even if they are not subscribed to this service.

Personal Data processed: Usage Data; email.

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

Category of Personal Information Collected Under the CCPA: Identifiers; Information about your activities on the Internet or other networks.

This type of processing constitutes:

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

Font Awesome (Fonticons, Inc. )

Font Awesome is a font style display service operated by Fonticons, Inc. which allows this Application to integrate such content within its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy.

Category of Personal Information Collected Under the CCPA: Information about your activities on the Internet or other networks.

This type of processing constitutes:

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

Cookie Policy

This Application makes use of Tracking Tools. To find out more, Users can consult the Cookie Policy.


Additional information for users

Legal basis for the processing
The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

  • the User has given consent for one or more specific purposes.
  • the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
  • the processing is necessary to comply with a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or for the exercise of official authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

In any case, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract


Learn more about retention time

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

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of such contract is completed.
  • Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer until such consent is withdrawn. In addition, the Data Controller may be obliged to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Your rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights with reference to the Data processed by the Data Controller.

In particular, within the limits provided for by law, the User has the right to:

  • withdraw your consent at any time. The User may revoke the consent to the processing of his/her Personal Data previously expressed.
  • object to the processing of their Data. You may object to the processing of your Data when it is done on a legal basis other than consent.
  • access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification. The User can verify the correctness of his/her Data and request that it be updated or corrected.
  • obtain the restriction of processing. You may request the restriction of the processing of your Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
  • obtain the erasure or removal of your Personal Data. The User may request the deletion of his/her Data by the Data Controller.
  • receive their Data or have them transferred to another Data Controller. The User has the right to receive his/her Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its unhindered transfer to another controller.
  • lodge a complaint. You may lodge a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information about the legal basis for the transfer of Data abroad, including to any international organization governed by international law or consisting of two or more countries, such as the UN, as well as about the security measures adopted by the Data Controller to protect their Data.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of official authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing on grounds related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reason. If Users object to processing for direct marketing purposes, Personal Data is no longer processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise your rights

To exercise their rights, Users may address a request to the Data Controller’s contact details indicated in this document. The request is free of charge and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, erasure or restriction of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller shall notify the User of these recipients if he/she requests it.


Additional information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other information that may differ or conflict contained in the privacy policy.

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

Your rights under the Federal Act on the Protection of Personal Data

Users may exercise certain rights relating to their data within the limits of the law, including the following:

  • right of access to Personal Data;
  • the right to object to the processing of their Personal Data (which also allows Users to request the restriction of the processing of Personal Data, the erasure or destruction of Personal Data, the prohibition of disclosure of Personal Data to third parties);
  • the right to receive your Personal Data and to transfer it to another controller (data portability);
  • the right to request rectification of incorrect Personal Data.

How to exercise these rights

Any requests to exercise the User’s rights may be addressed to the Data Controller through the contact details provided in this document. These requests are free of charge and the Owner will respond as soon as possible, providing Users with the information required by law.


Additional Information for Users in Brazil

This section of the document supplements and complements the information contained in the rest of the privacy policy and is provided by the entity operating this Application and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “us”, “our” or “our”).
This section applies to all Users in Brazil (such Users are referred to hereinafter simply as “you”, “your”, “you” or “your”), pursuant to the “Lei Geral de Proteção de Dados” and, for such Users, prevails over any other information that may differ or conflict contained in this privacy policy.
In this part of the document, the term “personal information” as defined by the LGPD is used.

Legal bases on which we process your personal information

We only process your personal information where one of the legal bases for such processing applies. The legal bases are as follows:

  • your consent to the processing activities in question;
  • compliance with legal obligations that we are required to meet;
  • the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
  • studies conducted by research institutions, preferably carried out on anonymized personal information;
  • the performance of a contract and related pre-contractual obligations, if you are a party to such a contract;
  • the exercise of our rights in court, administrative proceedings or arbitration;
  • the defense or physical safety of you or a third party;
  • health protection – in the context of procedures put in place by health entities or professionals;
  • our legitimate interest, provided that your fundamental rights and freedoms are not overridden by those 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 which categories of personal information are processed, you can refer to the “Details on the processing of Personal Data” section of this document.

Why we process your personal information

To find out why we process your personal information, please refer to the “Details on the Processing of Personal Data” and “Purposes of the Processing of the Data Collected” sections of this document.

Your privacy rights in Brazil, how to submit a request and how we will handle it

Your privacy rights in Brazil

You have the right to:

  • obtain confirmation of the existence of processing activities concerning your personal information;
  • access your personal information;
  • obtain rectification of your incomplete, inaccurate or out-of-date personal information;
  • obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is processed contrary to the provisions of the LGPD;
  • obtain information about whether you can give or withhold your consent and the consequences thereof;
  • obtain information about third parties with whom we share your personal information;
  • obtain, in response to your explicit request, the portability of your personal information (with the exception of anonymized information) to other providers of products or services, provided that our trade and trade secrets are safeguarded;
  • obtain erasure of the personal information processed where the processing has been carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 LGPD applies;
  • withdraw your consent at any time;
  • lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
  • object to processing activities in cases where such processing is not carried out in accordance with the provisions of the law;
  • request clear and adequate information about the criteria and procedures used in automated decision-making; and
  • request review of decisions that harm your interests, made solely on the basis of automated decision-making of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you be subjected to any unfavourable treatment in any way, as a result of exercising your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and how quickly we will handle your request

We will do our best to respond to your request as soon as possible.
In any event, if it is impossible for us to do so, we will ensure that we inform you of the factual or legal reasons that prevent us from immediately complying with or following up on your request. If we do not process your personal information, we will indicate the natural or legal person to whom you should address your requests, if we are able to do so.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please ensure that you specify whether you prefer to receive your personal information electronically or in paper form.
You will also need to let us know if you would like an immediate response, in which case you will receive a simplified response, or if you need a full disclosure.
In the latter case, we will respond within 15 days from the time of your request, providing you with all the information regarding the origin of your personal information, the confirmation or not of the existence of personal information concerning you, all the criteria used for the processing and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you decide to submit a request for Rectification, erasure, anonymization or blocking of personal information, we will ensure that we immediately notify the other parties with whom we have shared your personal information of your request so that they can in turn comply with your request – except where such disclosure would be impossible or unduly burdensome for us.

Transfer of Personal Information Outside of Brazil Where Permitted by Law

We may transfer your personal information outside of Brazil in the following cases:

  • when the transfer is necessary for international legal cooperation between intelligence services, investigative bodies and criminal procedure bodies, as provided for by the instruments made available by international law;
  • when the transfer is necessary to protect your life or limb or that of a third party;
  • when the transfer is authorised by the ANPD;
  • where the transfer arises from an obligation assumed in the context of an international cooperation agreement;
  • when the transfer is necessary for the exercise of public policy or for the performance of a public service;
  • when the transfer is necessary for the fulfilment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in guidizial, administrative or arbitration proceedings.

Further information for California consumers

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

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

This part of the document uses the 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: internet or other electronic network activity information and inferences drawn from other personal 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.


urther 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: internet information and inferred information

We do not collect sensitive data.

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

Why we process your personal data

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

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

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

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

Sale of your personal data

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

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

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

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

Processing of your personal data for targeted advertising

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

Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications; advertisements based on the context of a consumer’s current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer’s request for information or feedback; 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: internet information and inferred information

We do not collect sensitive data.

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

Why we process your personal data

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

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

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

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

For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the 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: internet information and inferred information

We do not collect sensitive data.

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

Why we process your personal data

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

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

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

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

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

Sale of your personal data

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

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

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

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

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

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

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

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

Processing of your personal data for targeted advertising

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

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CTDPA.

Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own 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.


Further information for Utah consumers

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

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

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

Categories of personal data processed

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

Categories of personal data we collect

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

We do not collect sensitive data.

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

Why we process your personal data

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

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

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

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

Sale of your personal data

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

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

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

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

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

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

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

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

Processing of your personal data for targeted advertising

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

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests” as defined by UCPA.

Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer’s request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”

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

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

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

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

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

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

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

  • access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
  • opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.

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

How to exercise your rights

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

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

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

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

How and when we are expected to handle your request

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

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.

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


More information about the treatment

Defence in court

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for the defense against abuses in the use of this Application or the related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

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

System Logs and Maintenance

For needs related to operation and maintenance, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

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

Changes to this privacy policy

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

If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information which, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is the information collected automatically through this Application (including by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

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

Interested

The natural person to whom the Personal Data relates.

Data Processor (or Data Processor)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)

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 and the means adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This application

The hardware or software tool through which Users’ Personal Data is collected and processed.

Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.


Legal References

This privacy policy has been drawn up on the basis of multiple legislative systems.

Unless otherwise specified, this privacy policy applies exclusively to this Application.