This Web Site collects certain Personal Data from its Users.
This document contains a section devoted to California consumers and their privacy rights.
This document contains a section devoted to Virginia consumers and their privacy-related rights.
This document contains a section devoted to Users residing in Brazil and their rights related to privacy.
This document can be printed using the print command found in the settings of any browser.
Data Controller
Welfness Srl
Via Cesare Lorenzi 2, 20099 Sesto San Giovanni (MI) P.iva 12676950962
Owner’s email address: info@welfness.com
Types of Data Collected
Among the Personal Data collected by this Web Site, either independently or through third parties, are: Usage Data; Tracking Tools; first name; last name; phone number; email; answers to questions; clicks; keypress events; motion sensor events; mouse movements; location relative to scrolling; and touch events.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site is mandatory. If the User refuses to provide it, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users in doubt about which Data are mandatory are encouraged to contact the Data Controller.
The possible use of Cookies – or other tracking tools – by this Website or the owners of third party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Web Site and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.
Method and place of processing of collected Data
Methods of processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Web Site (administrative, sales, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis for processing
The Controller processes Personal Data related to the User if one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
the processing is necessary for the performance of a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.
However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Location
The Data are processed at the Holder’s operational offices and at any other location where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the country in which the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.
The User can verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Data Controller by contacting it at the contact details given at the beginning.
Retention Period
Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.
Purposes of the Data collected
The User’s Data are collected to enable the Data Controller to provide the Service, to comply with legal obligations, to respond to requests or enforcement actions, to protect its rights and interests (or those of Users or third parties), to identify possible fraudulent or malicious activities, as well as for the following purposes: Displaying content from external platforms, Contacting the User and Protection from SPAM.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data”.
Details of Personal Data processing
Personal Data is collected for the following purposes and using the following services:
Contacting the User
Contact form (this Website)
The User, by filling in the contact form with his/her Data, consents to their use to respond to requests for information, quotations, or any other nature indicated in the header of the form.
Personal Data processed: surname; email; first name; telephone number.
Category of personal information collected under the CCPA: identifiers.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Protection against SPAM
This type of service analyses traffic on this Website, potentially containing Users’ Personal Data, in order to filter it from traffic, messages and content recognised as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data.
Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.
Personal Data processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scrolling position; answers to questions; Tracking Tools.
Place of Processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information; Indirect information.
Displaying content from external platforms
This type of service makes it possible to display content hosted on external platforms directly from the pages of this Website and to interact with them.
This type of service may nevertheless collect data on web traffic related to the pages where the service is installed, even when users are not using it.
Google Fonts
Google Fonts is a font style display service operated by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, which allows this Website to integrate such content within its pages.
Personal Data processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Font Awesome (Fonticons, Inc. )
Font Awesome is a font style display service operated by Fonticons, Inc. that enables this Website to integrate such content within its pages.
Personal Data processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Google Maps Widget
Google Maps is a map display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, which enables this Website to integrate such content within its pages.
Personal Data processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
YouTube Video Widget
YouTube is a video content display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, which enables this Website to integrate such content within its pages.
Personal Data processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Adobe Edge Web Fonts (Adobe Systems Incorporated)
Adobe Edge Web Fonts is a font style display service operated by Adobe Systems Incorporated that allows this Web Site to embed such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected under the CCPA: identifiers; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Adobe Fonts (Adobe Systems Incorporated)
Adobe Fonts is a font style display service operated by Adobe Systems Incorporated that allows this Web Site to embed such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected under the CCPA: identifiers; Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)
Fonts.com Web Fonts is a font style display service operated by Monotype Imaging Holdings Inc. that enables this Web Site to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
MyFonts (Monotype Imaging Holdings Inc.)
MyFonts is a font style display service operated by Monotype Imaging Holdings Inc. that enables this Website to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: United States – Privacy Policy.
Category of personal information collected under the CCPA: Internet information.
This type of processing constitutes:
a sale under the CCPA and the VCDPA
User Rights
Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, within the limits provided for by law, the User has the right to
withdraw consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed.
object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
access to their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
obtain the limitation of the processing. The User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
obtain the deletion or removal of their Personal Data. The User may request the deletion of its Data by the Data Controller.
receive their Data or have them transferred to another Data Controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller.
Propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right to object
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any reasons. Should Users object to the processing for direct marketing purposes, their Personal Data shall no longer be processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise rights
To exercise their rights, Users may address a request to the Controller’s contact details indicated in this document. The request may be filed free of charge and the Controller will reply as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, cancellation or restriction of processing shall be communicated by the Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Controller shall inform the User of such recipients if he so requests.
Further information on treatment
Legal defence
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory phases of such proceedings to defend against abuses in the use of this Web Site or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
Specific disclosures
At the User’s request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Responding to “Do Not Track” requests
This Website does not support “Do Not Track” requests.
To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details it has. Please therefore consult this page frequently, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Information for Users residing in Brazil
This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this Website and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “our” or “us”).
The provisions contained in this section apply to all Users who are residents of Brazil, within the meaning of the “Lei Geral de Proteção de Dados” (such Users are referred to hereinafter simply as “you”, “your”, “you” or “your”). For such Users, these provisions shall prevail over any divergent or conflicting provisions contained in this privacy policy.
In this part of the document, the term “personal information” as defined by the Lei Geral de Proteção de Dados (LGPD) is used.
Legal bases under which we process your personal information
We process your personal information only if there is a legal basis for such processing. The legal bases are the following
your consent to the processing activities in question;
the fulfilment of legal obligations we are required to comply with;
the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
studies conducted by research organisations, preferably carried out on anonymised personal information;
the performance of a contract and related pre-contractual obligations, if you are a party to such contract;
the exercise of our rights in court, administrative proceedings or arbitration;
the defence or physical safety of you or a third party;
the protection of your health – in the context of procedures carried out by healthcare entities or professionals;
our legitimate interests, provided that your fundamental rights and freedoms do not override those interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of personal information we process, you can refer to the ‘Details of Personal Information Processing’ section in this document.
Why we process your personal information
To learn why we process your personal information, please refer to the “Details of Personal Information Processing” and “Purposes of Personal Information Processing” sections of this document.
Your privacy rights in Brazil, how to submit a request and how it will be handled by us
Your rights relating to privacy in Brazil
You have the right to:
Obtain confirmation of the existence of processing activities concerning your personal information;
Access your personal information;
obtain rectification of your incomplete, inaccurate or outdated personal information;
Obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or information that is processed contrary to the provisions of the LGPD;
obtain information regarding the possibility of giving or refusing your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your explicit request, portability of your personal information (except anonymised information) to other providers of products or services, provided that our trade and business secrets are safeguarded
obtain the erasure of your personal information processed where the processing has been carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply
withdraw your consent at any time;
lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
object to processing activities in cases where such processing is not carried out in accordance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used in automated decision-making; and
request a review of decisions affecting your interests, made solely on the basis of automated decision-making processes of your personal information. These include decisions to outline your personal, professional, consumer or creditor profile, or other aspects of your personality.
You will never be discriminated against, or suffer any treatment that is unfavourable to you in any way, as a result of exercising your rights.
How to make a request
You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.
How and how quickly we will handle your request
We will endeavour to respond to your request as quickly as possible.
However, if it is impossible for us to do so, we will be sure to inform you of the factual or legal reasons why we cannot immediately comply or follow up on your request. In the event that your personal information is not processed by us, if we are able to do so, we will inform you of the natural or legal person to whom your request should be addressed.
If you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please make sure you specify whether you prefer to receive your personal information in electronic or paper format.
You should also let us know whether you would like an immediate response, in which case you will receive a simplified response, or whether you would like a full disclosure.
In the latter case, we will reply within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, confirmation or otherwise of the existence of personal information about you, all the criteria used for processing and the purposes of such processing, while safeguarding our commercial and industrial secrets.
In the event that you decide to submit a request for rectification, erasure, anonymisation or blocking of your personal information, we will ensure that we immediately inform the other parties with whom we have shared your personal information of your request so that they may in turn comply with your request – unless such communication is impossible or unduly burdensome for us.
Transfer of personal information outside Brazil in cases permitted by law
We may transfer your personal information outside the Brazilian territory in the following cases
when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as provided by the instruments made available by international law;
when the transfer is necessary to defend your life or physical safety or that of a third party;
when the transfer is authorised by the ANPD;
when the transfer results from an obligation undertaken in the context of an international cooperation agreement;
when the transfer is necessary for the exercise of a public order or the performance of a public service;
when the transfer is necessary for the fulfilment of a legal obligation, the performance of a contract and related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.
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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the “California Consumer Privacy Act of 2018” (the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, 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 defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
Categories of personal information collected, used, sold, or shared
In this section we summarize the categories of personal information that we’ve collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, internet information and inferred information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this 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 won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this 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 Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this 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 notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a 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. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Information for Virginia 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 controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, internet information and inferred information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data. You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a minor under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
. Information for Users residing in Brazil
This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Website and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as ” we”, “our” or “our”).
The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the “Lei Geral de Proteção de Dados” (such Users are referred to below simply as “you”, “your”, “you” or “your”). For these Users, these provisions prevail over any other possibly divergent or conflicting provision contained in this privacy policy.
This part of the document uses the term “personal information” as defined by the Lei Geral de Proteção de Dados (LGPD).
Legal bases under which we process your personal information
We only process your personal information if one of the legal grounds for such processing exists. The legal bases are as follows:
your consent to the processing activities in question;
compliance with legal obligations that we are required to comply with;
the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
studies conducted by research institutions, preferably carried out on anonymised personal information;
the execution of a contract and the related pre-contractual obligations, if you are a party to this contract;
the exercise of our rights in court, administrative proceedings or arbitration;
your defense or physical safety or that of a third party;
health protection – in the context of procedures implemented by entities or professionals in the health sector;
our legitimate interest, provided your fundamental rights and freedoms do not override those interests; And
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out which categories of personal information are processed, you can refer to the “Details on the processing of Personal Data” section in this document.
Why we treat your personal information
To find out why we process your personal information, please refer to the “Details on the processing of personal data” and “Purpose of processing the collected data” sections in this document.
Your privacy rights in Brazil, how to make a request and how it will be handled by us
Your privacy rights in Brazil
You have the right to:
obtain confirmation of the existence of processing activities concerning your personal information;
access your personal information;
obtain the rectification of your incomplete, inaccurate or outdated personal information;
obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is processed contrary to the provisions of the LGPD;
obtain information regarding the possibility of giving or refusing your consent and the related consequences;
obtain information about the third parties with whom we share your personal information;
obtain, upon your explicit request, the portability of your personal information (with the exception of anonymised information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
obtain the cancellation of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply;
withdraw your consent at any time;
lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And
request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.
You will never be discriminated against, nor will you suffer any treatment that is unfavorable to you in any way, following the exercise of your rights.
How to submit a request
You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.
How and in what time we will handle your request
We will do our best to answer your request as soon as possible.
In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons which prevent us from immediately complying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the natural or legal person to whom to address your requests.
In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require complete disclosure.
In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the treatment and the purposes of such processing, while safeguarding our commercial and industrial secrets.
In the event that you decide to submit a request for rectification, deletion, anonymization or blocking of personal information, we will make sure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn satisfy your request – except in cases where such communication is impossible or excessively burdensome for us.
Transfer of personal information outside Brazil in cases permitted by law
We may transfer your personal information outside the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as required by the tools made available by international law;
when the transfer is necessary to defend the life or physical integrity of you or of third parties;
when the transfer is authorized by the ANPD;
when the transfer arises from an obligation assumed in the context of an international cooperation agreement;
when the transfer is necessary for the exercise of a public order or for the performance of a public service;
when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.
Definitions and legal references
Personal Data (or Data)
Personal data is any information which, directly or indirectly, including in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
User
The individual who uses this Website which, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refer.
Data Controller (or Processor)
The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Controller, as set out in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.
This Web Site (or this Application)
The hardware or software tool through which Users’ Personal Data are collected and processed.
Service
The Service provided by this Web Site as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference in this document to the European Union shall be deemed to include all current member states of the European Union and the European Economic Area.
Cookies
Cookies are tracking tools that consist of small pieces of data stored within the User’s browser.
Tracking Tool
A Tracking Tool is any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.
Legal references
This Privacy Policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise stated, this privacy policy applies exclusively to this Website.