Privacy Policy www.unesco.it/
This application collects some personal data from users.
This document contains a section dedicated to consumers in California and their rights concerning privacy.
This document contains a section dedicated to consumers in Virginia and their rights concerning privacy.
This document contains a section dedicated to consumers in Colorado and their rights concerning privacy.
This document contains a section dedicated to consumers in Connecticut and their rights concerning privacy.
This document contains a section dedicated to consumers in Utah and their rights concerning privacy.
This document contains a section dedicated to users in Switzerland and their rights concerning privacy.
This document contains a section dedicated to users residing in Brazil and their rights concerning privacy.
This document can be printed using the print function in any browser.
Data Controller
Italian National Commission for UNESCO
Via di Sant’Apollinare, 8
00186 ROME
TEL: 06 6873261
Data Controller email: segretariato.cniu@unesco.it
Types of Data collected
The Personal Data collected by this Application autonomously or via third parties includes: email; tracking tools; usage data.
Full details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such Data.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during use of this Application.
Unless otherwise specified, the provision of all Data requested by this Application is obligatory. If the User refuses to communicate it, it may be impossible for the Application to provide the Service. If this Application indicates certain Data as optional, Users are free to abstain from communicating this specific Data with no impact on the availability or operativity of the Service.
Users who are uncertain as to which Data is obligatory are encouraged to contact the Data Controller. The possible use of Cookies or other tracking tools by this Application or by the third-party service providers accessed by this Application is for the purpose of providing the Service requested by the User, in addition to other purposes described in this document and in the Cookie Policy.
The User assumes responsibility for third-party personal data obtained, published or shared via this Application.
How and where collected Data is processed
Processing methods
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Data processing is carried out by means of computer and/or electronic means, using organizational methods and logics strictly related to the indicated purposes. In some cases, in addition to the Data Controller, other subjects involved in the organization of this Application (administrative, sales, marketing and legal staff and system administrators), as well as external subjects (third-party technical service providers, postal couriers, hosting providers, IT companies, communications agencies) designated by the Data Controller, if necessary, as Processing Managers, may have access to Data. An updated list of Processing Managers is always available from the Data Controller upon request.
Location
Data are processed at the Data Controller’s operational offices and at any other location where the parties involved in the processing are located. For more information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the User’s. For more information about the processing location, Users may refer to the section on the details of Personal Data processing.
Data Retention Period
Unless otherwise indicated in this document, Personal Data are processed and retained for the time required for the purpose for which they were collected, and may be kept for a longer period by reason of legal obligations or based on Users’ consent.
Purposes of Data Processing
Users’ Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to enforcement requests or actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, and for the following purposes: Contacting the User, Accessing accounts on third party services, Creating and managing this Application, and Displaying content from external platforms.
For detailed information on the purposes of data processing and Personal Data processed for each purpose, Users can refer to the section “Details of Personal Data Processing”.
Facebook permissions requested by this Application
This Application may request certain Facebook permissions that allow it to perform actions with the User’s Facebook account and collect information from it, including Personal Data. This service allows the Application to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information on the following permissions, refer to documentation of Facebook permissions and the Facebook privacy policy.
The following permissions are requested:
Basic information
The basic information of the registered Facebook User, which normally includes the following Data: ID, name, image, gender and localization language, and, in some cases Facebook “Friends”. If the User has made additional Data publicly available, it will be available.
Tracking tools
Tracking Tool means any technology – e.g., cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting – that allows User tracking, for example by collecting or storing information on the User’s device.
Details of Personal Data Processing
Personal Data are collected for the following purposes and utilizing the following services:
Accessing accounts on third-party services
These types of services allow this Application to take Data from your accounts on third-party services and carry out actions with them.
These services are not activated automatically, but require the User’s express permission.
Accessing Facebook account (Meta Platforms Ireland Limited)
This service allows this Application to connect with the User’s Facebook account, provided by Meta Platforms Ireland Limited.
Permissions requested: Tracking Tools.
Processing location: Ireland – Privacy Policy.
Category of personal data collected under CCPA: information relating to activities on the internet or other networks.
This type of processing constitutes:
- a sale under CCPA, CPA and CTDPA
Accessing X account (X Corp.)
This service allows this Application to connect with the User’s X account, provided by X Corp.
Personal Data processed: Tracking Tools.
Processing location: United States – Privacy Policy.
Category of personal data collected under CCPA: information relating to activities on the internet or other networks.
This type of processing constitutes:
- a sale under CCPA, CPA and CTDPA
Contacting the User
Contact form (this Application)
By filling in the Contact form with their own Data, Users consent to their Data’s use to respond to requests for information, estimates, or of any other nature stated in the form heading.
Personal Data processed: email.
Category of personal data collected under CCPA: identifiers.
This type of processing constitutes:
- a sale under CCPA, VCDPA, CPA, CTDPA and UCPA
Creation and management of this Application
The main components of this Application are created and managed directly by the Data Controller using software indicated below.
WordPress (self-hosted) (this Application)
This Application is developed and managed by the Data Controller using a CMS (Content Management System) software called WordPress.
Personal Data processed: email.
Category of personal data collected under CCPA: identifiers.
This type of processing constitutes:
- a sale under VCDPA, CPA, CTDPA and UCPA
- a sharing under CCPA
- targeted advertising under VCDPA, CPA, CTDPA and UCPA
Viewing content from external platforms
This type of service allows Users to view and interact with content hosted on external platforms directly from the pages of this Application. Such services are often referred to as widgets, which are small elements inserted into 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 collect data on web traffic to the pages where the service is installed, even when users are not utilizing it.
Instagram Widget (Meta Platforms Ireland Limited)
Instagram is an image sharing service operated by Meta Platforms Ireland Limited that allows this Application to integrate such content into its pages.
Personal Data processed: Usage data; Tracking Tools.
Processing location: Ireland – Privacy Policy.
Category of personal data collected under CCPA: information relating to activities on the internet or other networks.
This type of processing constitutes:
- a sale under CCPA, VCDPA, CPA, CTDPA and UCPA
YouTube Video Widget (Google Ireland Limited)
YouTube is a video content sharing service operated by Google Ireland Limited that allows this Application to integrate such content into its pages.
Personal Data processed: Usage data; Tracking Tools.
Processing location: Ireland – Privacy Policy.
Category of personal data collected under CCPA: information relating to activities on the internet or other networks.
This type of processing constitutes:
- a sale under CCPA, VCDPA, CPA, CTDPA and UCPA
Cookie Policy
This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.
Further information for Users
Legal basis for data processing
The Data Controller will process the User’s Personal Data under one of the following conditions:
- the User has given consent for one or more specific purposes. Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or one of the other legal bases specified below, as long as the User does not object (“opt-out”). However, this does not apply when the processing of Personal Data is regulated by European Personal Data Protection legislation;
- processing is necessary for the performance of a contract with the User and/or the performance of measures prior to a contract;
- processing is necessary to comply with a legal obligation to which the Data Controller is subject;
- processing is necessary to carry out a task in the public interest or in the exercise of official authority vested in the Data Controller;
- processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
However, the Data Controller can be asked at any time to clarify the concrete legal basis of any processing, and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Further information on the retention period
Unless otherwise indicated in this document, Personal Data are processed and retained for the time required for the purpose for which they were collected and may be kept for a longer period by reason of legal obligations or based on 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 that contract is completed.
- Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until that interest is achieved. Users can obtain further information regarding the legitimate interest pursued by the Data Controller in the pertinent sections of this document or by contacting the Controller.
When processing is based on User consent, the Data Controller may retain Personal Data for a longer period, until that consent is withdrawn. Additionally, the Data Controller may be required to retain Personal Data for a longer period in order to comply with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, once this period has ended, the rights of access, deletion and rectification and the right to Data portability can no longer be exercised.
Users’ rights
Users have certain rights with regard to Data processed by the Data Controller.
Specifically, within the limits established by law, Users have the right to:
- withdraw consent at any time. Users can withdraw previously-expressed consent to the processing of their Personal Data.
- object to the processing of their Data. Users may object to processing of their Data done under a legal basis other than consent.
- access their own Data. Users have the right to obtain information on Data processed by the Data Controller and on certain aspects of the processing, and to receive a copy of the Data processed.
- verify and request correction. Users can verify the correctness of their Data and request that it be updated or corrected.
- limit processing. Users can request that the processing of their Data be limited. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
- obtain the deletion or removal of their Personal Data. Users can request that the Data Controller delete their Data.
- receive their Data or have it transferred to another Data Controller. Users have the right to receive their Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller.
- file a complaint. Users can file complaints with the appropriate data protection supervisory authority or take legal action.
Users have the right to obtain information regarding the legal basis for the transfer of Data to other countries, including to any international organization governed by international law or set up by two or more countries, such as the UN; Users can also obtain information regarding security measures taken by the Data Controller to protect their Data.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller, or in pursuit of the legitimate interest of the Data Controller, Users have the right to object to the processing on grounds pertaining to their specific situation.
Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge and without giving any reasons. If Users object to processing for direct marketing purposes, their Personal Data will no longer be processed for such purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise rights
To exercise their rights, Users can send a request to the addresses given for the Data Controller in this document. The request is free of charge and the Data Controller will respond as soon as possible and in any case within one month, providing the User with all information required by law. Any rectification, deletion or limitation of processing will be communicated by the Data Controller to any recipients to which the Personal Data has been transmitted, unless this proves impossible or requires a disproportionate effort. The Data Controller will notify the User of such recipients upon request.
Further information for users in Switzerland
This section applies to Users in Switzerland, for whom it supersedes any other possibly different or conflicting information contained in the Privacy Policy.
Further details regarding categories of Data processed, purposes of processing, categories of recipients of Personal Data, if any, the retention period, and other information about Personal Data can be found in the section of this document entitled “Details of Personal Data Processing”.
Users’ rights under the Federal Data Protection Act
Users have certain rights regarding their data within the limitations of the law, including:
- right to access Personal Data;
- right to object to the processing of Personal Data (which also gives Users the right to request the limitation of processing of Personal Data, the deletion or destruction of Personal Data, and the non-disclosure of Personal Data to third parties);
- right to receive their Personal Data and transfer them to another Data Controller (data portability);
- right to request rectification of incorrect Personal Data.
How to exercise these rights
Any requests to exercise Users’ rights may be addressed to the Data Controller through the contact information provided in this document. Such requests are free of charge and the Controller will respond as soon as possible, providing Users with the information required by law.
Further information for users in Brazil
This section of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the legal entity operating this Application and, where applicable, its parent company, subsidiaries and affiliates (for the purposes of this section collectively referred to with “we,” “our,” or “us”).
This section applies to all Users in Brazil (hereafter simply “you” or “your”), pursuant to the Lei Geral de Proteção de Dados; for such Users, this section prevails over any other possibly different or conflicting information contained in this privacy policy.
This part of the document utilizes the term “personal information” as defined by the above-mentioned LGPD.
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: identifiers and internet or other electronic network activity information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
For our purposes, the word “targeted advertising” means “displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests” as defined by the VCDPA.
Please note that according to the VCDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications; advertisements based on the context of a consumer’s current search query, visit to a website or online application; advertisements directed to a consumer in response to the consumer’s request for information or feedback; or processing personal data solely for measuring or reporting advertising performance, reach, or frequency”.
To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act” (the “CPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.
For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer’s request for information or feedback; advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring ” (also known as “The Connecticut Data Privacy Act” or the “CTDPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CTDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.
For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.
For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own web sites or online applications; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer’s request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
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: identifiers and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
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.
Legal basis for the processing of your personal information
We process your personal information solely where one of the legal bases for such processing exists. The legal bases are the following:
- your consent for the processing activities in question;
- the fulfilment of legal obligations we are required to meet;
- the implementation of rules dictated by law, regulations, contracts, agreements, or other similar legal instruments;
- studies conducted by research institutions, preferably using anonymized personal information;
- the performance of a contract and relative pre-contractual measures, if you are a party to that contract;
- the exercise of our rights in court, administrative proceedings or arbitrations;
- the defense or protection of the physical safety of your or a third party;
- health protection – in the context of procedures implemented by health care institutions or professionals;
- our legitimate interest, provided that your fundamental rights and freedoms do not override said interest; and
- credit protection.
To learn more about legal bases, you can contact us at any time using the contact information provided in this document.
Categories of personal information processed
To find out what categories of personal information are processed, you can refer to the “Details of Personal Data Processing” section of this document.
Why we process your personal information
To find out why we process your personal information, refer to the “Details of Personal Data Processing” and “Purposes of processing of collected data” sections of this document.
Your privacy rights in Brazil, how to submit a request and how we will handle requests
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 personal information if it is incomplete, inaccurate or out of date;
- obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or information processed contrary to the provisions of the LGPD;
- obtain information concerning the possibility of giving or withholding your consent and the relative consequences;
- obtain information concerning the third parties with which we share your personal information;
- obtain, upon your explicit request, portability of your personal information (except anonymized information) to other product or service providers, provided that our trade and industry secrets are safeguarded;
- obtain the deletion of personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions in Article 16 of the LGPD apply
- withdraw your consent at any time;
- file a complaint concerning your personal information with the ANPD (National Data Protection Authority) or a consumer protection organization;
- object to processing activities if processing is not carried out in accordance with the law;
- request clear and sufficient information concerning the criteria and procedure utilized in the context of automated decision-making processes; and
- request the review of decisions that harm your interests, made solely on the basis of automated decision-making processes applied to your personal information. These include decisions to delineate your personal, professional, consumer or creditor profile, or other facets of your personality.
You will never be subject to discrimination or to any treatment that is unfavorable to you 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 information provided in this document or through your legal representative.
How and how quickly we will handle your request
We will respond to your request as quickly as possible.
If this proves impossible, we will be sure to inform you of the factual or legal reasons that hinder us from immediately fulfilling or following up on your request. In the event that your personal information is not processed by us, we will direct you to the natural or legal person to whom your requests should be addressed, if we are able to do so.
If you decide to submit a request for access to or confirmation of the existence of processing of personal information, please be sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know whether you would like an immediate response, in which case you will receive a simplified response, or whether you require a full report instead. In the latter case, we will respond within 15 days from the time of your request, providing you with full information regarding the origin of your personal information, confirmation of whether or not we know of the existence of personal information about you, all criteria used for processing and the purposes of such processing, without disclosing our proprietary trade and industrial information.
If you decide to submit a request for rectification, deletion, anonymization or blocking of personal information, we will be sure to immediately inform other parties with whom we have shared your personal information of your request so that they can in turn comply with it – except in cases where such communication is impossible or unduly burdensome for us.
Transfer of personal information outside Brazil in cases permitted by law
We may transfer your personal information outside Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between intelligence services and/or criminal investigation and prosecution authorities, in accordance with international law;
- when the transfer is necessary to protect your life or physical safety or that of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer arises from an obligation assumed as part of an international cooperation agreement;
- when the transfer is necessary for the execution of public policy or the performance of a public service;
- when the transfer is necessary for the fulfillment of a legal obligation, the performance of a contract and related pre-contractual measures, or the normal exercise of rights in judicial, administrative or arbitration proceedings.
Further information on processing
Legal defense
Users’ Personal Data may be used by the Data Controller in court or in the preparatory stages of establishing a possible defense against Users’ improper utilization of this Application or related Services.
Users declare that they are aware that the Data Controller may be obliged to disclose Data by order of public authorities.
Specific notices
Upon User request, in addition to the information contained in this privacy policy, this Application may provide Users with additional and contextual notices concerning specific Services or the collection and processing of Personal Data.
System log and maintenance
For operational and maintenance purposes, 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 IP address.
Information not contained in this policy
Further information concerning the processing of Personal Data can be requested at any time from the Data Controller using the contact information indicated in this document.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time, notifying Users on this page and, if possible, on this Application, and, when technically and legally feasible, sending a notice to Users through one of the contacts in its possession. Therefore, please consult this page frequently, referring to the most recent modification date at the bottom of the page.
When changes affect processing legally based on 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 that, directly, indirectly, or in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage data
This is information automatically collected through this Application (including by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers utilized by Users who connect 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 server’s response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (e.g. the time spent on each page) and the details of the itinerary the user followed within the Application, in particular the sequence of pages consulted, and parameters concerning the User’s operating system and IT environment.
User
The individual who utilizes this Application and who, unless otherwise specified, is also the Data Subject.
Data Subject
The natural person to whom Personal Data refer.
Data Processor (or Processor)
The natural or legal person, public administration or any other organization that processes personal data for the Data Controller, as explained in this privacy policy.
Data Controller (or Controller)
The natural or legal person, public administration, service or other organization that, individual or in concert with others, determines the purposes and means of personal data processing and the tools utilized, including security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the controller of this Application.
This Application
The hardware or software by which Users’ Personal Data are collected and processed.
Service
The Service provided by this Application as defined in relative terms (if present) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document is understood to extend to all current member states of the European Union and the European Economic Area.
Cookies
Cookies are Tracking Tools that consist of small pieces of data within the User’s browser.
Tracking Tool
A Tracking Tool is any technology – e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or saving information on the User’s device.
Legal references
This privacy policy is based on multiple legislative systems.
Where not otherwise specified, this privacy policy applies exclusively to this Application.