Privacy

Effective date: Sep 1, 2020

Owner and Data Controller

city mates

Furrenstrasse 5

6442 Gersau

Ownercontact email: info@citymates.app

Types of Data collected

Among the types of Personal Data that this Applicationcollects, by itself or through third parties, there are: first name; last name;phone number; username; password; profile picture; Usage Data; payment info;email address; purchase history; Trackers; User ID; date of birth;geography/region; country; city; gender; company name; physical address; state;county; ZIP/Postal code; geographic position; language.

Complete details on each type ofPersonal Data collected are provided in the dedicated sections of this privacypolicy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely providedby the User, or, in case of Usage Data, collected automatically when using thisApplication.

Unless specified otherwise, all Datarequested by this Application is mandatory and failure to provide this Data maymake it impossible for this Application to provide its services. In cases wherethis Application specifically states that some Data is not mandatory, Users arefree not to communicate this Data without consequences to the availability orthe functioning of the Service.

Users who are uncertain about which Personal Data ismandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by thisApplication or by the owners of third-party services used by this Applicationserves the purpose of providing the Service required by the User, in additionto any other purposes described in the present document and in the CookiePolicy.

Users are responsible for any third-party Personal Dataobtained, published or shared through this Application.

Mode and place of processing the Data Methods of processing

The Owner takes appropriate securitymeasures to prevent unauthorized access, disclosure, modification, orunauthorized destruction of the Data.

The Data processing is carried out using computers and/orIT enabled tools, following organizational procedures and modes strictlyrelated to the purposes indicated. In addition to the Owner, in some cases, theData may be accessible to certain types of persons in charge, involved with theoperation of this Application (administration, sales, marketing, legal, systemadministration) or external parties (such as third-party technical serviceproviders, mail carriers, hosting providers, IT companies, communicationsagencies) appointed, if necessary, as Data Processors by the Owner. The updatedlist of these parties may be requested from the Owner at any time.

Place

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

Depending on the User's location, data transfers mayinvolve transferring the User's Data to a country other than their own. To findout more about the place of processing of such transferred Data, Users cancheck the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Datashall be processed and stored for as long as required by the purpose they havebeen collected for and may be retained for longer due to applicable legalobligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow theOwner to provide its Service, comply with its legal obligations, respond toenforcement requests, protect its rights and interests (or those of its Usersor third parties), detect any malicious or fraudulent activity, as well as thefollowing: Registration and authentication, Hosting and backend infrastructure,Managing contacts and sending messages, Social features, Handling payments,Analytics, Displaying content from external platforms, Advertising andContacting the User.

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

Detailed information on the processing ofPersonal Data

Personal Data is collected for the following purposes andusing the following services:

Advertising

This type of service allows User Datato be utilized for advertising communication purposes. These communications aredisplayed in the form of banners and other advertisements on this Application,possibly based on User interests.

This does not mean that allPersonal Data are used for this purpose. Information and conditions of use areshown below. Some of the services listed below may use Trackers to identifyUsers or they may use the behavioral retargeting technique, i.e.

displaying ads tailored to the User’sinterests and behavior, including those detected outside this Application. Formore information, please check the privacy policies of the relevant services.

Services of this kind usually offer the possibility to optout of such tracking. In addition to any opt-out feature offered by any of theservices below, Users may learn more on how to generally opt out ofinterest-based advertising within the dedicated section "How to opt-out ofinterest-based advertising" in this document.

Google AdSense (Google Ireland Limited)

Google AdSense is an advertising service provided byGoogle Ireland Limited. This service uses the “DoubleClick” Cookie, whichtracks use of this Application and User behavior concerning ads, products andservices offered. Users may decide to disable all the DoubleClick Cookies bygoing to: Google Ad Settings.

In order to understand Google's use of data, consult Google's partner policy.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – PrivacyPolicy – Opt Out.

Category of personal information collected according to theCCPA: internet or other electronic network activity information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

- a sharing according tothe CCPA

- targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

Analytics

The services contained in this section enable the Owner tomonitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Universal Analytics) (GoogleIreland Limited)

Google Analytics (UniversalAnalytics) is a web analysis service provided by Google Ireland Limited(“Google”). Google utilizes the Data collected to track and examine the use ofthis Application, to prepare reports on its activities and share them with otherGoogle services.

Google may use the Data collected to contextualize andpersonalize the ads of its own advertising network.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – OptOut.

Category of personal information collected according to theCCPA: internet or other electronic network activity information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Contacting the User
Contact form (this Application)

By filling in the contact form with their Data, the Userauthorizes this Application to use these details to reply to requests forinformation, quotes or any other kind of request as indicated by the form’sheader.

Personal Data processed: city; company name; country;county; date of birth; email address; first name; gender; last name; phonenumber; physical address; state; User ID; ZIP/Postal code.

Category of personal information collected according to theCCPA: identifiers; commercial information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Displaying content from external platforms

This type of service allows you toview content hosted on external platforms directly from the pages of thisApplication and interact with them.

This type of service might still collect web traffic datafor the pages where the service is installed, even when Users do not use it.

Google Maps widget (Google Ireland Limited)

Google Maps is a maps visualization service provided byGoogle Ireland Limited that allows this Application to incorporate content ofthis kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to theCCPA: internet or other electronic network activity information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Handling payments

Unless otherwise specified, this Application processes anypayments by credit card, bank transfer or other means via external paymentservice providers. In general and unless where otherwise stated, Users arerequested to provide their payment details and personal information directly tosuch payment service providers. This Application isn't involved in thecollection and processing of such information: instead, it will only receive anotification by the relevant payment service provider as to whether payment hasbeen successfully completed.

Stripe (Stripe Payments Europe, Limited)

Stripe is a payment service provided by Stripe PaymentsEurope, Limited.

Personal Data processed: email address; first name; lastname; payment info; purchase history; Trackers; Usage Data.

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; commercial information; internet or other electronic networkactivity information.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and filesthat enable this Application to run and be distributed as well as to provide aready-made infrastructure to run specific features or parts of thisApplication.

Some services among those listed below, if any, may workthrough geographically distributed servers, making it difficult to determinethe actual location where the Personal Data are stored.

Firebase Cloud Firestore (Google LLC)

Firebase Cloud Firestore is a hosting and backend serviceprovided by Google LLC.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; internet or other electronic network activity information.

Firebase Cloud Functions (Google LLC)

Firebase Cloud Functions is a hosting and backend serviceprovided by Google LLC.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; internet or other electronic network activity information.

Firebase Cloud Storage (Google LLC)

Firebase Cloud Storage is a hosting service provided byGoogle LLC.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; internet or other electronic network activity information.

Managing contacts and sending messages

This type of service makes itpossible to manage a database of email contacts, phone contacts or any othercontact information to communicate with the User.

These services may also collect data concerning the dateand time when the message was viewed by the User, as well as when the Userinteracted with it, such as by clicking on links included in the message.

Firebase Cloud Messaging (Google LLC)

Firebase Cloud Messaging is a message sending serviceprovided by Google LLC. Firebase Cloud Messaging allows the Owner to sendmessages and notifications to Users across platforms such as Android, iOS, andthe web. Messages can be sent to single devices, groups of devices, or specifictopics or User segments.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

- a sharing according to the CCPA targeted advertising according to the VCDPA, CPA,CTDPA and UCPA

Firebase Notifications (Google LLC)

Firebase Notifications is a message sending serviceprovided by Google LLC. Firebase Notifications can be integrated with FirebaseAnalytics to target analytics-based audiences and track opening and conversionevents.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

- a sharing according tothe CCPA

- targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

Registration and authentication

By registering or authenticating, Users allow thisApplication to identify them and give them access to dedicated services.

Depending on what is described below, third parties mayprovide registration and authentication services. In this case, thisApplication will be able to access some Data, stored by these third-partyservices, for registration or identification purposes. Some of the serviceslisted below may also collect Personal Data for targeting and profilingpurposes; to find out more, please refer to the description of each service.

Firebase Authentication (Google LLC)

Firebase Authentication is a registration and authenticationservice provided by Google LLC. To simplify the registration and authenticationprocess, Firebase Authentication can make use of third-party identity providersand save the information on its platform.

Personal Data processed: first name; last name; password;phone number; profile picture; username.

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; audio, electronic, visual, thermal, olfactory, or similarinformation.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Sign in with Apple (Apple Inc.)

Sign in with Apple is a registration and authenticationservice provided by Apple Inc. In cases where Users are required to providetheir email address, Sign in with Apple may generate a private relay address onbehalf of Users that automatically forwards messages to their verified personalemail account - therefore shielding their actual email address from the Owner.

Personal Data processed: city; country; date of birth;email address; first name; geography/region; last name; password; phone number;profile picture; User ID.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers; geolocation data; audio, electronic, visual, thermal,olfactory, or similar information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Google OAuth (Google Ireland Limited)

Google OAuth is a registration and authentication serviceprovided by Google Ireland Limited and is connected to the Google network.

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

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Direct registration and profiling (thisApplication)

By registering or authenticating directly through thisApplication, Users allow this Application to identify them and give them accessto dedicated services. The Owner may process Data collected when Users registeror authenticate also for targeting and profiling purposes; to find out more, Userscan contact the Owner using the contact details provided in this document.

Personal Data processed: company name; country; date ofbirth; email address; first name; gender; geographic position; language; lastname; password; phone number; profile picture; state; User ID; username;ZIP/Postal code.

Category of personal information collected according to theCCPA: identifiers; commercial information; geolocation data; audio, electronic,visual, thermal, olfactory, or similar information; inferences drawn from otherpersonal information.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Social features
Firebase Dynamic Links (Google LLC)

Firebase Dynamic Links is a social feature provided byGoogle LLC. Dynamic Links are tracked within Firebase or Google Analytics forFirebase, which informs the Owner about the details of the User journey to andwithin this Application.

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

Place of processing: Switzerland – Privacy Policy.

Category of personal information collected according to theCCPA: identifiers.

This processing constitutes:

- a sale according to the CCPA, VCDPA, CPA,CTDPA and UCPA

Information on opting out of interest-basedadvertising

In addition to any opt-out feature provided by any of theservices listed in this document, Users may learn more on how to generally optout of interest-based advertising within the dedicated section of the CookiePolicy.

Further information about the processing of Personal Data
Push notifications

This Application may send push notifications to the User toachieve the purposes outlined in this privacy policy.

Users may in most cases opt-out of receivingpush notifications by visiting their device settings, such as the notificationsettings for mobile phones, and then change those settings for thisApplication, some or all of the apps on the particular device. Users must beaware that disabling push notifications may negatively affect the utility ofthis Application. Sellinggoods and services online

The Personal Data collected are used to provide the Userwith services or to sell goods, including payment and possible delivery. ThePersonal Data collected to complete the payment may include the credit card, thebank account used for the transfer, or any other means of payment envisaged.The kind of Data collected by this Application depends on the payment systemused.

CookiePolicy

This Application uses Trackers. To learn more, Users mayconsult the Cookie Policy.

Further Information for Users
Legal basis of processing

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

- Usershave given their consent for one or more specific purposes.

- provision of Data is necessary forthe performance of an agreement with the User and/or for any pre-contractualobligations thereof;

- processing is necessary for compliance with a legalobligation to which the Owner is subject;

- processing is related to a task that is carried out in thepublic interest or in the exercise of official authority vested in the Owner;

- processing is necessary for the purposes of the legitimateinterests pursued by the Owner or by a third party.

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

Further information about retention time

Unless specified otherwise in this document, Personal Datashall be processed and stored for as long as required by the purpose they havebeen collected for and may be retained for longer due to applicable legalobligation or based on the Users’ consent.

Therefore:

- PersonalData collected for purposes related to the performance of a contract betweenthe Owner and the User shall be retained until such contract has been fullyperformed.

- Personal Data collected for the purposes of the Owner’slegitimate interests shall be retained as long as needed to fulfill suchpurposes. Users may find specific information regarding the legitimateinterests pursued by the Owner within the relevant sections of this document orby contacting the Owner.

The Owner may be allowed to retain Personal Data for alonger period whenever the User has given consent to such processing, as longas such consent is not withdrawn. Furthermore, the Owner may be obliged toretain Personal Data for a longer period whenever required to fulfil a legalobligation or upon order of an authority.

Once the retention period expires, Personal Data shall bedeleted. Therefore, the right of access, the right to erasure, the right torectification and the right to data portability cannot be enforced afterexpiration of the retention period.

The rights of Users based on the General DataProtection Regulation (GDPR)

Users may exercise certain rights regarding their Dataprocessed by the Owner.

In particular, Users have the right to do the following, tothe extent permitted by law:

- Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given theirconsent to the processing of their Personal Data.

- Objectto processing of their Data. Users have the right to object to theprocessing of their Data if the processing is carried out on a legal basisother than consent.

- Accesstheir Data. Users have the right to learn if Data is being processed by theOwner, obtain disclosure regarding certain aspects of the processing and obtaina copy of the Data undergoing processing.

- Verifyand seek rectification. Users have the right to verify the accuracy oftheir Data and ask for it to be updated or corrected.

- Restrict theprocessing of their Data. Users have the right to restrict the processingof their Data. In this case, the Owner will not process their Data for anypurpose other than storing it.

- Have their PersonalData deleted or otherwise removed. Users have the right to obtain theerasure of their Data from the Owner.

- Receive their Dataand have it transferred to another controller. Users have the right toreceive their Data in a structured, commonly used and machine readable formatand, if technically feasible, to have it transmitted to another controllerwithout any hindrance.

- Lodge a complaint. Users have the right tobring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis forData transfers abroad including to any international organization governed bypublic 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.

Details about the right to object to processing

WherePersonal Data is processed for a public interest, in the exercise of anofficial authority vested in the Owner or for the purposes of the legitimateinterests pursued by the Owner, Users may object to such processing byproviding a ground related to their particular situation to justify theobjection.

Usersmust know that, however, should their Personal Data be processed for directmarketing purposes, they can object to that processing at any time, free ofcharge and without providing any justification. Where the User objects toprocessing for direct marketing purposes, the Personal Data will no longer beprocessed for such purposes. To learn whether the Owner is processing PersonalData for direct marketing purposes, Users may refer to the relevant sections ofthis document.

How to exercise these rights

Any requests to exercise User rights can be directed to theOwner through the contact details provided in this document. Such requests arefree of charge and will be answered by the Owner as early as possible andalways within one month, providing Users with the information required by law.Any rectification or erasure of Personal Data or restriction of processing willbe communicated by the Owner to each recipient, if any, to whom the PersonalData has been disclosed unless this proves impossible or involvesdisproportionate effort. At the Users’ request, the Owner will inform themabout those recipients.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and, for suchUsers, supersedes any other possibly divergent or conflicting informationcontained in the privacy policy.

Further details regarding the categories of Data processed,the purposes of processing, the categories of recipients of the personal data,if any, the retention period and further information about Personal Data can befound in the section titled “Detailedinformation on the processing of Personal Data” within this document.

The rights of Users according to the SwissFederal Act on Data Protection

Users may exercise certain rights regarding their Datawithin the limits of law, including the following:

- right of access to Personal Data;

- right to object to the processing of their PersonalData (which also allows Users to demand that processing of Personal Data berestricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);

- right to receive their PersonalData and have it transferred to another controller (data portability);

- right toask for incorrect Personal Data to be corrected.

How to exercise these rights

Any requests to exercise User rights can be directed to theOwner through the contact details provided in this document. Such requests arefree of charge and will be answered by the Owner as early as possible,providing Users with the information required by law.

Further information for Users in Brazil

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

This section applies to all Users inBrazil (Users are referred to below, simply as “you”, “your”, “yours”),according to the "Lei Geral de Proteção de Dados" (the"LGPD"), and for such Users, it supersedes any other possiblydivergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personalinformation“ as it is defined in the LGPD.

The grounds on which we process your personalinformation

We can process your personal information solely if we havea 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 lieswith us;

- the carrying out of public policiesprovided in laws or regulations or based on contracts, agreements and similarlegal instruments;

- studies conducted by research entities, preferably carried out on anonymized personalinformation;

- the carrying out of a contract and its preliminary procedures, incases where you are a party to said contract; the exercising of our rights injudicial, administrative or arbitration procedures;

- protection or physicalsafety of yourself or a third party;

- the protection of health – in procedures carried outby health entities or professionals; our legitimate interests, provided thatyour fundamental rights and liberties do not prevail over such interests; andcredit protection.

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

Categories of personal information processed

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

Why we process your personal information

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

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

You have the right to:

- obtain confirmation of the existence of processing activities on your personalinformation; access to your personal information;

- have incomplete, inaccurate or outdated personalinformation rectified;

- obtain the anonymization, blocking orelimination of your unnecessary or excessive personal information, or ofinformation that is not being processed in compliance with the LGPD;

- obtain information on thepossibility to provide or deny your consent and the consequences thereof;obtain information about the third parties with whom we share your personalinformation; obtain, upon your express request, the portability of yourpersonal information (except for anonymized information) to another service orproduct provider, provided that our commercial and industrial secrets aresafeguarded;

- obtain the deletion of your personalinformation being processed if the processing was based upon your consent,unless one or more exceptions provided for in art. 16 of the LGPD apply; revokeyour consent at any time;

- lodge a complaint related to yourpersonal information with the ANPD (the National Data Protection Authority) orwith consumer protection bodies;

- oppose a processing activity in cases where theprocessing is not carried out in compliance with the provisions of the law;request clear and adequate information regarding the criteria and proceduresused for an automated decision; and request the review of decisions made solelyon the basis of the automated processing of your personal information, whichaffect 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 otherwisesuffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rightsfree from any charge, at any time, by using the contact details provided inthis 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’llmake sure to communicate to you the factual or legal reasons that prevent usfrom immediately, or otherwise ever, complying with your requests. In caseswhere we are not processing your personal information, we will indicate to youthe physical or legal person to whom you should address your requests, if weare in the position to do so.

In the event that you file an access or personal information processing confirmation request, pleasemake sure that you specify whether you’d like your personal information to bedelivered in electronic or printed form.

You will also need to let us knowwhether you want us to answer your request immediately, in which case we willanswer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the timeof your request, providing you with all the information on the origin of yourpersonal information, confirmation on whether or not records exist, anycriteria used for the processing and the purposes of the processing, whilesafeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blockingrequest, we will make sure to immediately communicate your request to otherparties with whom we have shared your personal information in order to enablesuch third parties to also comply with your request — except in cases wheresuch communication is proven impossible or involves disproportionate effort onour side.

Transfer of personal information outside ofBrazil permitted by the law

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

- whenthe transfer is necessary for international legal cooperation between publicintelligence, investigation and prosecution bodies, according to the legalmeans provided by the international law; when the transfer is necessary toprotect your life or physical security or those of a third party; when thetransfer is authorized by the ANPD;

- when the transfer results from a commitment undertakenin an international cooperation agreement; when the transfer is necessary forthe execution of a public policy or legal attribution of public service; whenthe 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 arbitrationprocedures.

Further information for California consumers

This section of the document integrates with andsupplements the information contained in the rest of the privacy policy and isprovided by the business running this Application and, if the case may be, itsparent, subsidiaries and affiliates (for the purposes of this section referredto collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred tobelow, simply as “you”, “your”, “yours”), who are consumers residing in thestate of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), asupdated by the "California Privacy Rights Act" (the "CPRA")and subsequent regulations. For such consumers, this section supersedes anyother possibly divergent or conflicting information contained in the privacypolicy.

This part of the document uses the terms “personalinformation” (and “sensitive personal information”) as defined in theCalifornia Consumer Privacy Act (CCPA).

Notice at collection
Categories of personal information collected,used, sold, or shared

In this section we summarize thecategories of personal information that we've collected, used, sold, or sharedand the purposes thereof. You can readabout these activities in detail in the section titled “Detailed information onthe processing of Personal Data” within this document.

Informationwe collect: the categories of personal information we collect

We have collected the following categories of personalinformation about you: identifiers, commercial information, internet or otherelectronic network activity information, geolocation data, audio, electronic,visual, thermal, olfactory, or similar information and inferences drawn fromother personal information.

We have collected the following categories of sensitivepersonal information: username, password, payment info, password, username andpassword

We will not collect additional categories of personalinformation without notifying you.

Your rightto limit the use or disclosure of your sensitive personal information and howyou can exercise it

You have the right to request that we limit the use ordisclosure of your sensitive personal information to only that which isnecessary to perform the services or provide the goods, as is reasonablyexpected by an average consumer.

We can also use your sensitive personal information toperform specific purposes set forth by the law (such as, including but notlimited to, helping to ensure security and integrity; undertaking activities toverify or maintain the quality or safety of our service) and as authorized bythe relevant regulations.

Outside of the aforementioned specific purposes, you havethe right to freely request, at any time, that we do not use or disclose yoursensitive personal information. This means that whenever you ask us to stopusing your sensitive personal information, we will abide by your request and wewill instruct our service providers and contractors to do the same.

To fully exercise your right to limit the use or disclosureof your sensitive personal information you can contact us at any time, usingthe contact details provided in this document.

For a simplified method you can also use the privacychoices link provided on this Application.

We use any personal information collected from you inconnection with the submission of your request solely for the purposes ofcomplying with the request.

Once you have exercised this right, we are required to waitat least 12 months before asking whether you have changed your mind.

What are thepurposes for which we use your personal information?

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

We may also use your personal information for other reasonssuch as for commercial purposes (as indicated within the section “Detailedinformation on the processing of Personal Data” within this document), as wellas for complying with the law and defending our rights before the competentauthorities where our rights and interests are threatened or we suffer anactual damage.

We won’t process your information for unexpected purposes,or for purposes incompatible with the purposes originally disclosed, withoutyour consent.

How long dowe keep your personal information?

Unless stated otherwise inside the “Detailed information onthe processing of Personal Data” section, we will not retain your personalinformation for longer than is reasonably necessary for the purpose(s) theyhave been collected for.

How wecollect information: what are the sources of the personal information wecollect?

We collect the above-mentioned categories of personalinformation, either directly or indirectly, from you when you use thisApplication.

For example, you directly provide your personal informationwhen you submit requests via any forms on this Application. You also providepersonal information indirectly when you navigate this Application, as personalinformation about you is automatically observed and collected.

Finally, we may collect your personal information fromthird parties that work with us in connection with the Service or with thefunctioning of this Application and features thereof.

How we usethe information we collect: disclosing of your personal information with thirdparties for a business purpose

For our purposes, the word “third party” means a person whois not any of the following: a service provider or a contractor, as defined bythe CCPA.

We disclose your personal information with the thirdparties listed in detail in the sectiontitled “Detailed information on the processing of Personal Data” within thisdocument. These third parties are grouped and categorized in accordancewith the different purposes of processing.

Sale orsharing of your personal information

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

This means that, for example, a sale can happen whenever anapplication runs ads, or makes statistical analyses on the traffic or views, orsimply 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, makingavailable, transferring, or otherwise communicating orally, in writing, or byelectronic or other means, a consumer's personal information by the business toa third party for cross-context behavioral advertising, whether or not formonetary or other valuable consideration, including transactions between abusiness and a third party for cross-context behavioral advertising for thebenefit of a business in which no money is exchanged”, as defined by the CCPA.

Please note that the exchange of personal information witha service provider pursuant to a written contract that meets the requirementsset by the CCPA, does not constitute a sale or sharing of your personalinformation.

Your rightto opt out of the sale or sharing of your personal information and how you canexercise it

We sell or share your personal information with the thirdparties listed in detail in the sectiontitled “Detailed information on the processing of Personal Data” within thisdocument. These third parties are grouped and categorized in accordancewith the different purposes of processing.

You have the right to opt out of thesale or sharing of your personal information. This means that whenever yourequest us to stop selling or sharing your personal information, we will abideby your request.

Such requests can be made freely, at any time, withoutsubmitting any verifiable request.

To fully exercise your right to opt out, you cancontact us at any time using the contact details provided in this document. Fora simplified opt-out method you can also use the privacy choices link providedon this Application.

If you want to submit requests to opt out of the sale orsharing of personal information via a user-enabled global privacy control, likethe Global Privacy Control (“GPC”), you are free to do so and we will abideby such request in a frictionless manner (as defined in the CPRA regulations).The GPC consists of a setting or extension in the browser or mobile device andacts as a mechanism that websites can use to indicate they support the GPCsignal. If you want to use GPC, you can download and enable it via a participatingbrowser orbrowser extension. More information about downloading GPC is available here.

We use any personal information collected from you inconnection with the submission of your opt-out request solely for the purposesof complying with the opt-out request.

Once you have opted out, we are required to wait at least12 months before asking whether you have changed your mind.

What are thepurposes for which we use your personal information?

We may use your personal information to allow theoperational functioning of this Application and features thereof (“businesspurposes”). In such cases, your personal information will be processed in a fashionnecessary 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 reasonssuch as for commercial purposes (as indicated within the section “Detailedinformation on the processing of Personal Data” within this document), as wellas for complying with the law and defending our rights before the competentauthorities where our rights and interests are threatened or we suffer anactual damage.

We won’t process your information for unexpected purposes,or for purposes incompatible with the purposes originally disclosed, withoutyour consent.

How long dowe keep your personal information?

Unless stated otherwise inside the “Detailed information onthe processing of Personal Data” section, we will not retain your personalinformation for longer than is reasonably necessary for the purpose(s) theyhave been collected for.

Your privacy rights under the California Consumer Privacy Act and howto exercise them
The right to access personal information: theright 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 fromwhich the personal information is collected; the purposes for which we use yourinformation; to whom we disclose such information; the specific pieces ofpersonal information we have collected about you.

You also have theright to know what personal information is sold or shared and to whom. Inparticular, you have the right to request two separate lists from us where wedisclose:

- the categories of personal information that we sold or shared about you and thecategories of third parties to whom the personal information was sold orshared; the categories of personal information that we disclosed about you fora business purpose and the categories of persons to whom it was disclosed for abusiness purpose.

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

If we deliver our response electronically, the informationenclosed will be "portable", i.e. delivered in an easily usableformat to enable you to transmit the information to another entity withouthindrance — provided that this is technically feasible.

The right to request the deletion of yourpersonal information

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

If no legal exception applies, as a result of exercisingyour right, we will delete your personal information and notify any of ourservice providers and all third parties to whom we have sold or shared thepersonal information to do so — provided that this is technically feasible anddoesn’t involve disproportionate effort.

The right to correct inaccurate personalinformation

You have the right to request that we correct anyinaccurate personal information we maintain about you, taking into account thenature of the personal information and the purposes of the processing of thepersonal information.

The right to opt out of sale or sharing ofpersonal information and to limit the use of your sensitive personalinformation

You have the right to opt out of the sale or sharing ofyour personal information. You also have the right to request that we limit ouruse or disclosure of your sensitive personal information.

The right of no retaliation following opt-out orexercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising yourrights under the CCPA. This means that we will not discriminate against you,including, but not limited to, by denying goods or services, charging you adifferent price, or providing a different level or quality of goods or servicesjust because you exercised your consumer privacy rights.

However, if you refuse to provide your personal informationto us or ask us to delete or stop selling your personal information, and thatpersonal information or sale is necessary for us to provide you with goods orservices, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer youpromotions, discounts, and other deals in exchange for collecting, keeping, orselling your personal information, provided that the financial incentiveoffered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submityour verifiable request to us by contacting us via the details provided in thisdocument.

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

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

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

Making a verifiable consumer request does not require youto create an account with us. We will use any personal information collectedfrom you in connection with the verification of your request solely for thepurposes of verification and shall not further disclose the personalinformation, retain it longer than necessary for purposes of verification, oruse it for unrelated purposes.

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

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

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

How and when we are expected to handle yourrequest

We will confirm receipt of your verifiable request within10 days and provide information about how we will process your request.

We will respond to your request within 45 days of itsreceipt. Should we need more time, we will explain to you the reasons why, andhow much more time we need. In this regard, please note that we may take up to90 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 wedisclose information beyond the 12-month period, and we will provide them toyou unless doing so proves impossible or would involve a disproportionateeffort.

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

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

Further information for Virginia consumers

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

This section applies to all Users (Users are referred tobelow, simply as “you”, “your”, “yours”), who are consumers residing in theCommonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the"VCDPA"), and, for such consumers, it supersedes any other possiblydivergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” asdefined in the VCDPA.

Categories of personal data processed

In this section, we summarize thecategories of personal data that we've processed and the purposes thereof. You can read about these activities indetail in the section titled “Detailed information on the processing of PersonaData” within this document.

Categories of personal data we collect

We have collected the following categories of personaldata: identifiers, commercial information, internet information, geolocationdata, sensorial information and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal datawithout notifying you.

Why we process your personal data

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

We won’t process your information forunexpected purposes, or for purposes incompatible with the purposes originallydisclosed, without your consent.

You can freely give, deny, or withdraw such consent at anytime using the contact details provided in this document.

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

We share your personal data with thethird parties listed in detail in thesection titled “Detailed information on the processing of Personal Data” withinthis document. These third parties are grouped and categorized inaccordance 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 thanthe consumer, controller, processor, or an affiliate of the processor or thecontroller" 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 athird party“ as defined by the VCDPA.

Please note that according to theVCDPA, the disclosure of personal data to a processor that processes personaldata on behalf of a controller does not constitute a sale. In addition, otherspecific exceptions set forth in the VCDPA may apply, such as, but not limitedto, the disclosure of personal data to a third party for the provision of aproduct or service requested by you.

As specified in the “Detailed information on the processingof Personal Data” section of this document, our use of your personalinformation may be considered a sale under VCDPA.

Your rightto 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 personaldata. This means that whenever you request us to stop selling your data, wewill abide by your request. To fully exercise your right to opt out you cancontact us at any time using the contact details provided in this document.

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

Processing of your personal data for targetedadvertising

For our purposes, the word "targeted advertising"means "displaying advertisements to you where the advertisement isselected based on personal data obtained from your activities over time andacross nonaffiliated websites or online applications to predict yourpreferences or interests" as defined by the VCDPA.

Please note that according to the VCDPA, targetedadvertising does not include: “advertisements based on activities within acontroller's own websites or online applications; advertisements based on thecontext of a consumer's current search query, visit to a website or onlineapplication; advertisements directed to a consumer in response to theconsumer's request for information or feedback; or processing personal datasolely for measuring or reporting advertising performance, reach, orfrequency”.

To find out more details on the processing of your personaldata for targeted advertising purposes, you can read the section titled“Detailed information on the processing of Personal Data” within this document.

Your rightto opt out of the processing of your personal data for targeted advertising andhow you can exercise it

You have the right to opt out of the processing of yourpersonal data for targeted advertising. This means that whenever you ask us tostop processing your data for targeted advertising, we will abide by yourrequest. To fully exercise your right to opt out you can contact us at anytime, using the contact details provided in this document.

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

Your privacy rights under the Virginia ConsumerData Protection Act and how to exercise them

You may exercise certain rights regarding your dataprocessed 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 processingyour personal data. You also have the right to access such personal data.

- correctinaccurate personal data. You have the right to request that we correct anyinaccurate personal data we maintain about you, taking into account the natureof 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 ofyour personal data. We will provide your personal data in a portable andusable 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 oftargeted advertising, the sale ofpersonal data, or profiling infurtherance of decisions that produce legal or similarly significant effectsconcerning you.

- non-discrimination.We will not discriminate against you for exercising your rights under theVCDPA. 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 goodsor 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 stopselling your personal data, and that personal data or sale is necessary for usto provide you with goods or services, we may not be able to complete thattransaction. To the extent permitted by the law, we may offer a differentprice, rate, level, quality, or selection of goods or services to you,including offering goods or services for no fee, if you have exercised yourright to opt out, or our offer is related to your voluntary participation in abona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submityour request to us by contacting us via the contact details provided in thisdocument.

For us to respond to your request, we need to know who youare.

We will not respond to any request if we are unable toverify your identity using commercially reasonable efforts and thereforeconfirm that the personal data in our possession actually relate to you. Insuch cases, we may request that you provide additional information which isreasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create anaccount with us. However, we may require you to use your existing account. Wewill use any personal data collected from you in connection with your requestsolely for the purposes of authentication, without further disclosing thepersonal data, retaining it longer than necessary for purposes ofauthentication, or using it for unrelated purposes.

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

How and when we are expected to handle yourrequest

We will respond to your request without undue delay, but inall cases and at the latest within 45 days of its receipt. Should we need moretime, 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 yourrequest.

Should we deny your request, we will explain to you thereasons behind our denial without undue delay, but in all cases and at thelatest within 45 days of receipt of the request. It is your right to appealsuch decision by submitting a request to us via the details provided in thisdocument. Within 60 days of receipt of the appeal, we will inform you inwriting of any action taken or not taken in response to the appeal, including awritten explanation of the reasons for the decisions. If the appeal is deniedyou may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for upto two requests per year. If your request is manifestly unfounded, excessive orrepetitive, we may charge a reasonable fee or refuse to act on the request. Ineither case, we will communicate our choices and explain the reasons behindthem.

Further information for Colorado consumers

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

This section applies to all Users (Users are referred tobelow, simply as “you”, “your”, “yours”), who are consumers residing in theState of Colorado, according to the “Colorado Privacy Act" (the"CPA"), and, for such consumers, it supersedes any other possiblydivergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” asdefined in the CPA.

Categories of personal data processed

In this section, we summarize thecategories of personal data that we've processed and the purposes thereof. You can read about these activities indetail in the section titled “Detailed information on the processing of PersonaData” within this document.

Categories of personal data we collect

We have collected the following categories of personal data:identifiers, commercial information, internet information, geolocation data,sensorial information and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal datawithout notifying you.

Why we process your personal data

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

We won’t process your information forunexpected purposes, or for purposes incompatible with the purposes originallydisclosed, without your consent.

You can freely give, deny, or withdraw such consent at anytime using the contact details provided in this document.

How we use the data we collect: sharing of yourpersonal 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 thedifferent purposes of processing.

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

Sale of your personal data

As specified in the “Detailed information on the processingof Personal Data” section of this document, our use of your personal data maybe considered a sale under the CPA.

For our purposes, the word "sale","sell", or "sold" means "the exchange of personal datafor monetary or other valuable consideration by a controller to a thirdparty" as defined by the CPA.

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

Your rightto 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 personaldata. This means that whenever you request us to stop selling your data, wewill abide by your request.

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

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

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

Processing of your personal data for targetedadvertising

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

For our purposes, the word "targeted advertising"means "displaying to a consumer an advertisement that is selected based onpersonal data obtained or inferred over time from the consumer's activitiesacross nonaffiliated websites, applications, or online services to predictconsumer preferences or interests" as defined by CPA.

Please note that according to the CPA, targeted advertisingdoes not include: “advertisements directed to a consumer in response to theconsumer's request for information or feedback; advertisements based onactivities within a controller's own websites or online applications or anyaffiliated website or online application; advertisements based on the contextof a consumer's current search query, visit to an internet web site or onlineapplication; or processing personal data solely to measure or reportadvertising frequency, performance or reach”.

Your rightto opt out of the processing of your personal data for targeted advertising andhow you can exercise it

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

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

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

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

Universalopt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale ofpersonal data or the targeted advertising via a user-enabled global privacycontrol, like the Global Privacy Control (“GPC”), you are free to do so and we willabide by such request. The GPC consists of a setting or extension in thebrowser or mobile device and acts as a mechanism that websites can use toindicate they support the GPC signal. If you want to use GPC, you can downloadand enable it via a participating browser or browser extension. Moreinformation about downloading GPC is available here.

Your privacy rights under the Colorado PrivacyAct and how to exercise them

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

- optout of the processing of your personal data for the purposes of targetedadvertising, the sale of personal data, or profiling in furtherance ofdecisions that produce legal or similarly significant effects concerning you.

- access personal data. You have the right to request that weconfirm whether or not we are processing your personal data.

- You also have the right to access such personal data.

- correct inaccurate personal data. Youhave the right to request that we correct any inaccurate personal data wemaintain about you, taking into account the nature of the personal data and thepurposes of the processing of the personal data. request the deletion of yourpersonal data. You have the right to request that we delete any of yourpersonal data.

- obtain a copy of your personal data. We will provide yourpersonal data in a portable and usable format that allows you to transfer dataeasily to another entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decreasethe availability of, a product or service, based solely on the exercise of anyof your rights and unrelated to the feasibility or the value of a service.However, to the extent permitted by the law, we may offer a different price,rate, level, quality, or selection of goods or services to you, includingoffering goods or services for no fee, if our offer is related to yourvoluntary 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 submityour request to us by contacting us via the contact details provided in thisdocument.

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

We will not respond to any request if we are unable toverify your identity using commercially reasonable efforts and thereforeconfirm that the personal data in our possession actually relate to you. Insuch cases, we may request that you provide additional information which isreasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create anaccount with us. However, we may require you to use your existing account. Wewill use any personal data collected from you in connection with your requestsolely for the purposes of authentication, without further disclosing thepersonal data, retaining it longer than necessary for purposes ofauthentication, or using it for unrelated purposes.

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

How and when we are expected to handle yourrequest

We will respond to your request without undue delay, but inall cases and at the latest within 45 days of its receipt. Should we need moretime, 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 yourrequest.

Should we deny your request, we will explain to you thereasons behind our denial without undue delay, but in all cases and at thelatest within 45 days of receipt of the request. It is your right to appealsuch decision by submitting a request to us via the details provided in thisdocument. Within 45 days of receipt of the appeal, we will inform you inwriting of any action taken or not taken in response to the appeal, including awritten explanation of the reasons for the decisions. If the appeal is deniedyou may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for upto two requests per year.

Further information for Connecticut consumers

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

This section applies o all Users (Users are referred tobelow, simply as “you”, “your”, “yours”), who are consumers residing in theState of Connecticut, according to “An Act Concerning Personal Data Privacy andOnline Monitoring " (also known as "The Connecticut Data PrivacyAct" or the “CTDPA"), and, for such consumers, it supersedes anyother possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” asdefined in the CTDPA.

Categories of personal data processed

In this section, we summarize thecategories of personal data that we've processed and the purposes thereof. You can read about these activities in detailin 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 personaldata: identifiers, commercial information, internet information, geolocationdata, sensorial information and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal datawithout notifying you.

Why we process your personal data

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

We won’t process your information forunexpected purposes, or for purposes incompatible with the purposes originallydisclosed, without your consent.

You can freely give, deny, or withdraw such consent at anytime using the contact details provided in this document.

How we use the data we collect: sharing of yourpersonal 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 thedifferent purposes of processing.

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

Sale of your personal data

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

For our purposes, the word "sale","sell", or "sold" means "the exchange of personal datafor monetary or other valuable consideration by a controller to a thirdparty" as defined by the CTDPA.

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

Your rightto 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 personaldata. This means that whenever you request us to stop selling your data, wewill abide by your request.

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

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

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

Processing of your personal data for targetedadvertising

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

For our purposes, the word "targeted advertising"means "displaying to a consumer an advertisement that is selected based onpersonal data obtained or inferred over time from the consumer's activitiesacross non affiliated websites, applications, or online services to predictconsumer preferences or interests" as defined by CTDPA.

Please note that according to the CTDPA, targetedadvertising does not include: “advertisements based on activities within acontroller's own web sites or online applications; advertisements based on thecontext of a consumer's current search query, visit to an internet web site oronline application; advertisements directed to a consumer in response to the consumer'srequest for information or feedback; or processing personal data solely tomeasure or report advertising frequency, performance or reach”.

Your rightto opt out of the processing of your personal data for targeted advertising andhow you can exercise it

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

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

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

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

Universalopt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale ofpersonal data or the targeted advertising via a user-enabled global privacycontrol, like the Global Privacy Control (“GPC”), you are free to do so and we willabide by such request. The GPC consists of a setting or extension in thebrowser or mobile device and acts as a mechanism that websites can use toindicate they support the GPC signal. If you want to use GPC, you can downloadand enable it via a participating browser or browser extension. Moreinformation about downloading GPC is available here.

Your privacy rights under the Connecticut DataPrivacy Act and how to exercise them

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

accesspersonal data. You have the right to request that we confirm whether or not weare processing your personal data.

You also have the right to access such personal data.

correct inaccurate personal data. Youhave the right to request that we correct any inaccurate personal data wemaintain about you, taking into account the nature of the personal data and thepurposes of the processing of the personal data.

request the deletion of your personal data. You have theright 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 allowsyou to transfer data easily to another entity – provided that this istechnically feasible.

opt out of the processing of your personal data for thepurposes of targeted advertising, the sale of personal data, or profiling infurtherance of decisions that produce legal or similarly significant effectsconcerning you.

In any case, we will not increase the cost of, or decreasethe availability of, a product or service, based solely on the exercise of anyof your rights and unrelated to the feasibility or the value of a service.However, to the extent permitted by the law, we may offer a different price,rate, level, quality, or selection of goods or services to you, includingoffering goods or services for no fee, if our offer is related to yourvoluntary 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 submityour request to us by contacting us via the contact details provided in thisdocument.

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

We will not respond to any request if we are unable toverify your identity using commercially reasonable efforts and thereforeconfirm that the personal data in our possession actually relate to you. Insuch cases, we may request that you provide additional information which isreasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create anaccount with us. However, we may require you to use your existing account. Wewill use any personal data collected from you in connection with your requestsolely for the purposes of authentication, without further disclosing thepersonal data, retaining it longer than necessary for purposes ofauthentication, or using it for unrelated purposes.

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

How and when we are expected to handle yourrequest

We will respond to your request without undue delay, but inall cases and at the latest within 45 days of its receipt. Should we need moretime, 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 yourrequest.

Should we deny your request, we will explain to you thereasons behind our denial without undue delay, but in all cases and at thelatest within 45 days of receipt of the request. It is your right to appealsuch decision by submitting a request to us via the details provided in thisdocument. Within 45 days of receipt of the appeal, we will inform you inwriting of any action taken or not taken in response to the appeal, including awritten 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 upto one request per year.

Further information for Utah consumers

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

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

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

Categories of personal data processed

In this section, we summarize thecategories of personal data that we've processed and the purposes thereof. You can read about these activities indetail in the section titled “Detailed information on the processing of PersonaData” within this document.

Categories of personal data we collect

We have collected the following categories of personaldata: identifiers, commercial information, internet information, geolocationdata, sensorial information and inferred information

We do not collect sensitive data.

We will not collect additional categories of personal datawithout notifying you.

Why we process your personal data

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

How we use the data we collect: sharing of yourpersonal 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 thedifferent purposes of processing.

For our purposes, the word "third party" means"a person other than: the consumer, controller, or processor; or anaffiliate or contractor of the controller or the processor" as defined bythe UCPA.

Sale of your personal data

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

For our purposes, the word "sale","sell", or "sold" means "the exchange of personal datafor monetary or other valuable consideration by a controller to a thirdparty" as defined by the UCPA.

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

Your rightto 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 personaldata. This means that whenever you request us to stop selling your data, wewill abide by your request.

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

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

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

Processing of your personal data for targetedadvertising

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

For our purposes, the word "targeted advertising"means "displaying to a consumer an advertisement that is selected based onpersonal data obtained or inferred over time from the consumer's activitiesacross nonaffiliated websites, applications, or online services to predictconsumer preferences or interests" as defined by UCPA.

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

Your rightto opt out of the processing of your personal data for targeted advertising andhow you can exercise it

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

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

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

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

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

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

accesspersonal data. You have the right to request that we confirm whether or not weare processing your personal data.

You also have the right to access such personal data.

request the deletion of your personal data. You have theright to request that we delete any of your personal data.

obtain a copy of your personal data. We will provideyour personal data in a portable and usable format that allows you to transferdata easily to another entity – provided that this is technically feasible. optout of the processing of your personal data for the purposes of targetedadvertising or the sale of personal data.

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

How to exercise your rights

To exercise the rights described above, you need to submityour request to us by contacting us via the contact details provided in thisdocument.

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

We will not respond to any request if we are unable toverify your identity using commercially reasonable efforts and thereforeconfirm that the personal data in our possession actually relate to you. Insuch cases, we may request that you provide additional information which isreasonably necessary to authenticate you and your request. We may retain youremail address to respond to your request.

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

How and when we are expected to handle yourrequest

We will respond to your request without undue delay, but inall cases and at the latest within 45 days of its receipt. Should we need moretime, 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 yourrequest.

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

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

Additional information about Data collection and processing
Legal action

The User's Personal Data may be usedfor legal purposes by the Owner in Court or in the stages leading to possiblelegal action arising from improper use of this Application or the relatedServices.

The User declares to be aware that the Owner may berequired to reveal personal data upon request of public authorities.

Additional information about User's PersonalData

In addition to the information contained in this privacypolicy, this Application may provide the User with additional and contextualinformation concerning particular Services or the collection and processing ofPersonal Data upon request.

System logs and maintenance

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

Information not contained in this policy

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

Changes to this privacy policy

The Owner reserves the right to make changes to thisprivacy policy at any time by notifying its Users on this page and possiblywithin this Application 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 ofthe last modification listed at the bottom.

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

Further information for Users in Brazil

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

This section applies to all Users inBrazil (Users are referred to below, simply as “you”, “your”, “yours”),according to the "Lei Geral de Proteção de Dados" (the"LGPD"), and for such Users, it supersedes any other possiblydivergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personalinformation“ as it is defined in the LGPD.

The grounds on which we process your personalinformation

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

- your consent to the relevant processing activities;

- compliance with a legal orregulatory obligation that lies with us; the carrying out of public policiesprovided in laws or regulations or based on contracts, agreements and similarlegal instruments;

- studies conducted by researchentities, preferably carried out on anonymized personal information; thecarrying out of a contract and its preliminary procedures, in cases where youare a party to said contract; the exercising of our rights in judicial, administrativeor arbitration procedures; protection or physical safety of yourself or a thirdparty;

- the protection of health – in procedures carried outby health entities or professionals; our legitimate interests, provided thatyour fundamental rights and liberties do not prevail over such interests; andcredit protection.

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

Categories of personal information processed

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

Why we process your personal information

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

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

You have the right to:

- obtain confirmation of the existence of processing activities on your personalinformation; access to your personal information;

- have incomplete, inaccurate or outdated personalinformation 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 theconsequences thereof; obtain information about the third parties with whom weshare your personal information;

- obtain, upon your express request,the portability of your personal information (except for anonymizedinformation) to another service or product provider, provided that ourcommercial and industrial secrets are safeguarded;

- obtain the deletion of your personalinformation being processed if the processing was based upon your consent,unless one or more exceptions provided for in art. 16 of the LGPD apply; revokeyour consent at any time;

- lodge a complaint related to yourpersonal information with the ANPD (the National Data Protection Authority) orwith consumer protection bodies;

- oppose a processing activity in cases where theprocessing is not carried out in compliance with the provisions of the law;request clear and adequate information regarding the criteria and proceduresused for an automated decision; and request the review of decisions made solelyon the basis of the automated processing of your personal information, whichaffect 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 otherwisesuffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rightsfree from any charge, at any time, by using the contact details provided inthis 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’llmake sure to communicate to you the factual or legal reasons that prevent usfrom immediately, or otherwise ever, complying with your requests. In caseswhere we are not processing your personal information, we will indicate to youthe physical or legal person to whom you should address your requests, if weare in the position to do so.

In the event that you file an access or personal information processing confirmation request, pleasemake sure that you specify whether you’d like your personal information to bedelivered in electronic or printed form.

You will also need to let us knowwhether you want us to answer your request immediately, in which case we willanswer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the timeof your request, providing you with all the information on the origin of yourpersonal information, confirmation on whether or not records exist, anycriteria used for the processing and the purposes of the processing, whilesafeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blockingrequest, we will make sure to immediately communicate your request to otherparties with whom we have shared your personal information in order to enablesuch third parties to also comply with your request — except in cases wheresuch communication is proven impossible or involves disproportionate effort onour side.

Transfer of personal information outside of Brazil permitted by the law

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

- whenthe transfer is necessary for international legal cooperation between publicintelligence, investigation and prosecution bodies, according to the legalmeans provided by the international law; when the transfer is necessary toprotect your life or physical security or those of a third party; when thetransfer is authorized by the ANPD; when the transfer results from a commitmentundertaken in an international cooperation agreement; when the transfer isnecessary for the execution of a public policy or legal attribution of publicservice;

- when the transfer is necessary for compliance with a legalor regulatory obligation, the carrying out of a contract or preliminaryprocedures related to a contract, or the regular exercise of rights injudicial, administrative or arbitration procedures.

Definitions and legal references
Personal Data (or Data)

Any information that directly, indirectly, or in connectionwith other information — including a personal identification number — allowsfor the identification or identifiability of a natural person.

Usage Data

Information collected automatically through thisApplication (or third-party services employed in this Application), which caninclude: the IP addresses or domain names of the computers utilized by theUsers who use this Application, the URI addresses (Uniform ResourceIdentifier), the time of the request, the method utilized to submit the requestto the server, the size of the file received in response, the numerical codeindicating the status of the server's answer (successful outcome, error, etc.),the country of origin, the features of the browser and the operating systemutilized by the User, the various time details per visit (e.g., the time spenton each page within the Application) and the details about the path followedwithin the Application with special reference to the sequence of pages visited,and other parameters about the device operating system and/or the User's ITenvironment. User

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

DataSubject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

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

Data Controller (or Owner)

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

ThisApplication

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

Service

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

European Union (or EU)

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

Cookie

Cookies are Trackers consisting of small sets of datastored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, uniqueidentifiers, web beacons, embedded scripts, e-tags and fingerprinting thatenables the tracking of Users, for example by accessing or storing informationon the User’s device.

Legal information

This privacy statement has been prepared based onprovisions of multiple legislations.

This privacy policy relates solely to this Application, ifnot stated otherwise within this document.

Latest update: February 16, 2024