Privacy Policy

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PRIVACY NOTICE

Last updated __________



This privacy notice for __________ (‘we‘, ‘us‘, or ‘our), describes how and why we might collect, store, use, and/or share (‘process‘) your information when you use our services (‘Services‘), such as when you:
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at __________.


SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.


TABLE OF CONTENTS



1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • job titles
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • billing addresses
  • debit/credit card numbers
  • street address
  • country
  • region/state
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • health data
  • data about a person’s sex life or sexual orientation
  • student data
  • social security numbers or other government identifiers
  • information revealing religious or philosophical beliefs
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by PayPal , Paystack , Stripe and Woocommerce. You may find their privacy notice link(s) here: https://www.paypal.com/privacy/privacyhub, https://paystack.com/privacy, https://stripe.com/privacy and https://automattic.com/privacy/.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:
  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.

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  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?‘ below.
  • To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalised and relevant advertising content for our users
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
  • Affiliate Marketing Programs
  • Ad Networks
  • Data Analytics Services
  • Data Storage Service Providers
  • Payment Processors
  • Performance Monitoring Tools
  • Product Engineering & Design Tools
  • Retargeting Platforms
  • Sales & Marketing Tools
  • Social Networks
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers
  • Order Fulfilment Service Providers
  • Communication & Collaboration Tools
  • Cloud Computing Services

We also may need to share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: and other similar information. A full list of what we use information for can be found in this section and in the previous section titled ‘HOW DO WE PROCESS YOUR INFORMATION?‘. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?‘ above), in  and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than one (1) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at __________.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.

We will consider and act upon any request in accordance with applicable data protection laws.
 
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying ‘STOP’ or ‘UNSUBSCRIBE’ to the SMS messages that we send, or by contacting us using the details provided in the section ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?‘ below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a ‘resident’ as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as ‘non-residents’.

If this definition of ‘resident’ applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information

YES

C. Protected classification characteristics under California or federal law
Gender and date of birth

YES

D. Commercial information
Transaction information, purchase history, financial details, and payment information

YES

E. Biometric information
Fingerprints and voiceprints

NO

F. Internet or other similar network activity
Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements

NO

G. Geolocation data
Device location

NO

H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities

NO

I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information
Student records and directory information

NO

K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

L. Sensitive Personal Information

NO
 

We will use and retain the collected personal information as needed to provide the Services or for:
  • Category A – As long as the user has an account with us
  • Category B – As long as the user has an account with us
  • Category C – As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?

We collect and share your personal information through:
  • Social media cookies
More information about our data collection and sharing practices can be found in this privacy notice.

You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage.

You may contact us or by referring to the contact details at the bottom of this document.

If you are using an authorised agent to exercise your right to opt out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.

We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
  • Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.

  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?.

We have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:
  • Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

  • Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.

  • Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.

The categories of third parties to whom we sold personal information are:
  • Ad Networks
  • Affiliate Marketing Programs
  • Data Analytics Services
  • Retargeting Platforms
  • Social Networks
  • User Account Registration & Authentication Services

The categories of third parties to whom we shared personal information with are:
  • Ad Networks
  • Data Analytics Services
  • Social Networks
  • User Account Registration & Authentication Services
  • Retargeting Platforms

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:
  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights
  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
To exercise these rights, you can contact us or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

14. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

‘Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

‘Personal data’ means any information that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available information.

‘Sale of personal data’ means the exchange of personal data for monetary consideration.

If this definition ‘consumer’ applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services. To find out more, please visit the following links:
Your rights with respect to your personal data
  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)
We sell personal data to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings. You may contact us by email at __________, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.

If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at __________. Within sixty (60) days of receipt of an 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 your appeal if denied, you may contact the Attorney General to submit a complaint.

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at __________ or contact us by post at:

__________
__________
__________

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.
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This privacy policy was created using Termly’s Privacy Policy Generator.

Privacy Policy

Privacy Policy of http://www.mannettecoms.com

This Website collects some Personal Data from its Users.

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

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

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

Owner and Data Controller

mannettecom s.r.l.
Via Obuasi Central, 1 – 20121 Accra (Ghana)
Accra Chamber of Commerce
SC: 12987 Eur (fully paid up)
Legal Representative: Mawunyo K. A.

Owner contact email: mashie@mannette.com

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Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address; password; Tracker; Usage Data; Data communicated while using the service; device information; shopping history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; first name; last name; Invoicing information; Universally unique identifier (UUID).

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

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

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

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

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

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

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

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

Retention time

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

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
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The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

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

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Contacting the User, Registration and authentication provided directly by this Website, Access to third-party accounts, Analytics, Displaying content from external platforms, Managing contacts and sending messages, Managing support and contact requests, Hosting and backend infrastructure, Remarketing and behavioral targeting, Infrastructure monitoring, Handling payments, Commercial affiliation, Tag Management, Interaction with external social networks and platforms, Data transfer outside the EU, Interaction with live chat platforms, User database management, Interaction with data collection platforms and other third parties, Advertising, Registration and authentication, Managing web conferencing and online telephony, Content performance and features testing (A/B testing) and Information collection.

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

Facebook permissions asked by this Website

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

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

The permissions asked are the following:

Basic information

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

Email

Provides access to the User’s primary email address.

Detailed information on the processing of Personal Data

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

  • Access to third-party accountsThis type of service allows this Website to access Data from your account on a third-party service and perform actions with it.
    These services are not activated automatically, but require explicit authorization by the User.Facebook account access (Facebook, Inc.)This service allows this Website to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.Permissions asked: Email.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 3 months.Category of personal information collected according to CCPA: identifiers.Twitter account access (Twitter, Inc.)This service allows this Website to connect with the User’s account on the Twitter social network, provided by Twitter, Inc.Personal Data processed: email address.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: identifiers.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • AdvertisingThis type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
    In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.Microsoft Advertising (Microsoft Corporation)Microsoft Advertising is an advertising service provided by Microsoft Corporation.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Outbrain (Outbrain Inc.)Outbrain is an advertising service provided by Outbrain Inc.Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 1 year.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Taboola (Taboola Inc.)Taboola is an advertising service provided by Taboola Inc.Personal Data processed: Tracker; Usage Data.Place of processing: United States – Privacy Policy – Opt Out.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Smarter Click Overlays (Smarter Click Technology Ltd)Smarter Click Overlays is an advertising and behavioral targeting service provided by Smarter Click Technology Ltd that allows the Owner to engage Users who show signs of abandoning this Website without completing a purchase with prompt overlay notifications.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United Kingdom – Privacy Policy.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • AnalyticsThe services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.Matomo (this Website)Matomo is an analytics software used by this Website to analyze data directly without the help of third parties.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: internet information.Google Ads conversion trackingGoogle Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that connects data from the Google Ads advertising network with actions performed on this Website.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Analytics with anonymized IPGoogle Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Heap Analytics (Heap Inc.)Heap Analytics is an analytics service provided by Heap Inc.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Twitter Ads conversion tracking (Twitter, Inc.)Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Website.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.User ID extension for Google AnalyticsGoogle Analytics on this Website makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
    The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Website.
    The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.Personal Data processed: Tracker.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out; United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Analytics Advertising Reporting FeaturesGoogle Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users’ ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Analytics Demographics and Interests reportsGoogle Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google’s use of cookies by visiting Google’s Ads Settings.Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.LinkedIn conversion tracking (LinkedIn Corporation)LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website.Personal Data processed: device information; Tracker; Usage Data.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Commercial affiliationThis type of service allows this Website to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
    Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Website.
    For details of which data are collected, please refer to the privacy policy of each service.ReferralCandy (Anafore Pte. Ltd.)ReferralCandy is a commercial affiliation service provided by Anafore Pte. Ltd.Personal Data processed: email address; first name; last name; Tracker; Usage Data.Place of processing: Singapore – Privacy Policy.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Admitad (Admitad AG)Admitad is a commercial affiliation service provided by Admitad AG.Personal Data processed: Cookies; Universally unique identifier (UUID); Usage Data.Place of processing: Switzerland – Privacy Policy – Opt out.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Contacting the UserMailing List or Newsletter (this Website)By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.Personal Data processed: email address.Legal basis for processing: Consent.Category of personal information collected according to CCPA: identifiers.Freshchat-Freshsales integration (Freshworks, Inc.)If a User provides their email address through Freshchat, a live chat platform, the User’s email address will be added to Freshsales, a customer relationship and contact management service. Both services are provided by Freshworks, Inc.
    The provision of the email address within Freshchat is voluntary and serves the purpose of being contacted for the fulfilling of support requests.Personal Data processed: email address.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: identifiers.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Content performance and features testing (A/B testing)The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Website.Google Optimize (Google Ireland Limited)Google Optimize is an A/B testing service provided by Google Ireland Limited (“Google”). Google may use Personal Data to contextualize and personalize the ads of its own advertising network.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: Ireland – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Data transfer outside the EUThe Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
    Users can inquire with the Owner to learn which legal basis applies to which specific service.Data transfer to countries that guarantee European standards (this Website)If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
    The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission’s website.Personal Data processed: various types of Data.Category of personal information collected according to CCPA: internet information.Data transfer abroad based on standard contractual clauses (this Website)If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
    This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.Personal Data processed: various types of Data.Category of personal information collected according to CCPA: internet information.
  • Displaying content from external platformsThis type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
    This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.Swiftype (Swiftype Inc.)Swiftype is a search engine embedding service provided by Swiftype Inc. that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Headway widget (Oskar Krawczyk/Piotr Zalewa)Headway widget is a content visualization service provided by Headway and Oskar Krawczyk/Piotr Zalewa.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: Poland – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.GitHub button and social widgets (GitHub Inc.)The GitHub button and social widgets are services allowing interaction with the GitHub and Gist services provided by GitHub, Inc.Personal Data processed: Usage Data.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.YouTube video widgetYouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.CodePen widget (CodePen, Inc.)CodePen is a code visualization and hosting service provided by CodePen, Inc. that allows this Website to incorporate content of this kind on its pages.Personal Data processed: Cookies; Usage Data.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Wistia widget (Privacy Mode) (Wistia, Inc.)Wistia is a video content visualization service provided by Wistia, Inc. that allows this Website to incorporate content of this kind on its pages. This widget is set up in a way that ensures that Wistia only collects fully anonymized viewing data about Users on this Website unless they opt in to being tracked.Personal Data processed: Usage Data.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Handling paymentsUnless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.PayPal (PayPal Inc.)PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: See the PayPal privacy policy – Privacy Policy.Legal basis for Data transfer outside the EU: Binding corporate rules.Data retention period: Keeping the data as long as required by relevant national law.Category of personal information collected according to CCPA: internet information.Braintree (PayPal (Europe) S.a.r.l. et Cie, S.C.A.)Braintree is a payment service provided by Braintree, a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Consent.Place of processing: See the Braintree privacy policy – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as required by relevant national law.Category of personal information collected according to CCPA: internet information.
  • Hosting and backend infrastructureThis type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.DigitalOcean (DigitalOcean Inc.)DigitalOcean is a hosting service provided by DigitalOcean Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Legitimate interest.Place of processing: Netherlands – Privacy Policy; Germany – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as required by relevant national law.Category of personal information collected according to CCPA: internet information.Akamai Content Delivery Network (Akamai Technologies, Inc.)Akamai is a hosting service provided by Akamai Technologies, Inc.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 6 months.Category of personal information collected according to CCPA: internet information.iubenda Consent Solution (iubenda srl)iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.Personal Data processed: Data communicated while using the service.Legal basis for processing: Contract.Place of processing: Italy – Privacy Policy.Data retention period: Keeping the data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).Category of personal information collected according to CCPA: internet information.Amazon Web Services (AWS) (Amazon Web Services, Inc.)Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Legitimate interest.Place of processing: Ireland – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.A-CUBE API (A-CUBE S.R.L)A-CUBE API is a service provided by A-CUBE S.R.L that enables and facilitates the integration of this Website with the Italian Exchange System (ES) for the fulfillment of legal obligations. Personal Data are shared with A-CUBE API for the purpose of creating electronic invoices upon the fulfillment of a payment by the User.Personal Data processed: Invoicing information.Legal basis for processing: Legitimate interest.Place of processing: Italy – Privacy Policy.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: commercial information.MongoDB Cloud (MongoDB, Inc.)MongoDB Cloud is a hosting and backend service provided by MongoDB, Inc.Personal Data processed: Usage Data.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.
  • Information collectionZoomInfo WebSightsZoomInfo WebSights is an application visitors’ data exporting service provided by ZoomInfo Technologies LLC.

    Personal Data collected: Usage Data.

    Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.ZoomInfo EnrichZoomInfo Enrich is a lead enrichment service provided by ZoomInfo Technologies LLC.

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

    Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Infrastructure monitoringThis type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.New Relic (New Relic)New Relic is a monitoring service provided by New Relic Inc.
    The way New Relic is integrated means that it filters all traffic of this Website, i.e., communication between the Application and the User’s browser or device, while also allowing analytical data on this Website to be collected.Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: internet information.Datadog (Datadog, Inc.)Datadog is a monitoring service provided by Datadog, Inc.
    The way Datadog is integrated means that it filters all traffic of this Website, i.e., communication between the Application and the User’s browser or device, while also allowing analytical data on this Website to be collected.Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.Sentry (Functional Software, Inc. )Sentry is a monitoring service provided by Functional Software, Inc. .Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Legitimate interest.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: internet information.
  • Interaction with data collection platforms and other third partiesThis type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.Typeform widget (TYPEFORM S.L)The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.Personal Data processed: Data communicated while using the service; email address.Legal basis for processing: Consent.Place of processing: Spain – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Interaction with external social networks and platformsThis type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
    The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.Twitter Tweet button and social widgets (Twitter, Inc.)The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Facebook Like button and social widgets (Facebook, Inc.)The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 3 months.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Interaction with live chat platformsThis type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.Freshchat Widget (Freshworks, Inc.)The Freshchat Widget is a service for interacting with the Freshchat live chat platform provided by Freshworks, Inc.Personal Data processed: Data communicated while using the service; email address; Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Managing contacts and sending messagesThis type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.SparkPost (Message Systems, Inc.)SparkPost is an email address management and message sending service provided by Message Systems, Inc.Personal Data processed: email address; various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data for the duration of the contract (upon termination of the contract, if applicable, as long as required by the applicable law).Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Amazon Simple Email Service (Amazon)Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.Personal Data processed: email address.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as required by relevant national law.Category of personal information collected according to CCPA: identifiers.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Vero (Vero Holdings Australia Pty. Ltd.)Vero is an email address management and message sending service provided by Vero Holdings Australia Pty. Ltd.Personal Data processed: email address; Usage Data.Place of processing: Australia – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Managing support and contact requestsThis type of service allows this Website to manage support and contact requests received via email or by other means, such as the contact form.
    The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).Freshdesk (Freshworks, Inc.)Freshdesk is a support and contact request management service provided by Freshworks, Inc.Personal Data processed: Data communicated while using the service; various types of Data as specified in the privacy policy of the service.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: Keeping the data as long as necessary for the establishment, exercise or defense of legal claims.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Managing web conferencing and online telephonyThis type of service allows this Website to manage the deployment, administration, hosting, recording, distribution and analysis of online telephony and web conferencing in order to communicate with Users.
    The Personal Data collected depend on the information provided by the Users while using the respective service.These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.Livestorm (LIVESTORM SAS.)Livestorm is a web conferencing management service provided by LIVESTORM SAS. Livestorm may use cookies to track User behavior. Users can find more information on how to opt out of Livestorm cookie tracking on this page.Personal Data processed: Data communicated while using the service; email address.Legal basis for processing: Consent.Place of processing: France – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 3 years.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Registration and authenticationBy registering or authenticating, Users allow this Website to identify them and give them access to dedicated services.
    Depending on what is described below, third parties may provide registration and authentication services. In this case, this Website will be able to access some Data, stored by these third-party services, for registration or identification purposes.
    Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.Facebook Authentication (Facebook, Inc.)Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.Personal Data processed: various types of Data as specified in the privacy policy of the service.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Registration and authentication provided directly by this WebsiteBy registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.Direct registration (this Website)The User registers by filling out the registration form and providing the Personal Data directly to this Website.Personal Data processed: email address; password.Legal basis for processing: Consent.Legal basis for Data transfer outside the EU: No data transfer.Category of personal information collected according to CCPA: identifiers.
  • Remarketing and behavioral targetingThis type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.AdRoll (NextRoll, Inc.)AdRoll is an advertising service provided by AdRoll, Inc.Personal Data processed: device information; shopping history; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Adequacy decisions.Data retention period: 1 month.Category of personal information collected according to CCPA: identifiers; commercial information; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Ads RemarketingGoogle Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Remarketing with Google AnalyticsRemarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Twitter Remarketing (Twitter, Inc.)Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Facebook Custom Audience (Facebook, Inc.)Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.Personal Data processed: email address; Tracker.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: identifiers; internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Facebook Remarketing (Facebook, Inc.)Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.Personal Data processed: Tracker; Usage Data.Legal basis for processing: Consent.Place of processing: United States – Privacy Policy – Opt Out.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Tag ManagementThis type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
    This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.Segment (Segment Inc.)Segment is a tag management service provided by Segment.io, Inc.Personal Data processed: Tracker; Usage Data.Place of processing: United States – Privacy Policy.Data retention period: Keeping the data, for the time necessary to fulfill the purpose.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Tag Manager (Google Ireland Limited)Google Tag Manager is a tag management service provided by Google Ireland Limited.Personal Data processed: Usage Data.Place of processing: Ireland – Privacy Policy.Legal basis for Data transfer outside the EU: Standard data protection clauses adopted by the EU commission.Data retention period: 18 months.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • User database managementThis type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Website.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.Freshsales (Freshworks, Inc.)Freshsales is a User database management service provided by Freshworks, Inc.Personal Data processed: various types of Data as specified in the privacy policy of the service.Place of processing: United States – Privacy Policy.Category of personal information collected according to CCPA: internet information.This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

The rights of Users

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

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

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

Details about the right to object to processing

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

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

How to exercise these rights

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

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

Additional information about Data collection and processing

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

Additional information about User’s Personal Data

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

System logs and maintenance

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

Information not contained in this policy

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

How “Do Not Track” requests are handled

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

Changes to this privacy policy

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

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

Information for Californian consumers

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

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

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

Categories of personal information collected, disclosed or sold

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

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information and internet information.

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

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

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

For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, 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 Website and features thereof.

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

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

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

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

Sale of your personal information

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

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

Your right to opt out of the sale of personal information

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

Instructions to opt out of the sale of personal information

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

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

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

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

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

Your California privacy rights and how to exercise them

The right to know and to portability

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

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

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

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

The right to request the deletion of your personal information

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

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

How to exercise your rights

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

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

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

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

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

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

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

How and when we are expected to handle your request

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

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

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

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

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

Information for Users residing in Brazil

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

The grounds on which we process your personal information

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

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

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

Categories of personal information processed

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

Why we process your personal information

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

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

Your Brazilian privacy rights

You have the right to:

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

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

How to file your request

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

How and when we will respond to your request

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

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

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

Transfer of personal information outside of Brazil permitted by the law

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

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

Personal Data (or Data)

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

Usage Data

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

User

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

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

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

Data Controller (or Owner)

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

This Website (or this Application)

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

Service

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

European Union (or EU)

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

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.


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

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

Latest update: August 03, 2021

mannettecom hosts this content and only collects the Personal Data strictly necessary for it to be provided.

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