privacy-policy - italylift

TERMS AND CONDITIONS

For information about your collected personal data, the purposes, and the parties with whom the data is shared, contact the Data Controller.

For more information and to learn about your rights, you can also view the full version of this privacy policy here:

https://www.iubenda.com/privacy-policy/51001203

Data Controller

Italy Lift srl

Via Sardegna 1, 65010 Moscufo (PE) Italy

Owner's email address: info@italylift.com

Types of Data collected

The Data Controller does not provide a list of types of Personal Data collected.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information notices displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.

Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to provide it, it may be impossible for this Website to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from communicating such Data, without any consequence on the availability or operation of the Service.

Users who have doubts about which Data is mandatory are encouraged to contact the Owner. The possible use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website and guarantees that they have the right to communicate or disclose them, releasing the Owner from any liability towards third parties.

Methods and place of processing of the collected Data

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal staff, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may also have access to the Data, appointed if necessary as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on Personal Data protection;

the processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;

the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is always possible to request the Data Controller to clarify the specific legal basis of each processing and, in particular, to specify whether the processing is based on law, provided for by a contract, or necessary to conclude a contract.

Place

The Data are processed at the operational offices of the Controller and in any other place where the parties involved in the processing are located. For further information, contact the Controller.

The User's Personal Data may be transferred to a country different from the one in which the User is located. For further information about the location of processing, the User can refer to the section regarding details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can verify whether any of the transfers described above take place by examining the section of this document relating to details on the processing of Personal Data or by requesting information from the Data Controller using the contact details provided at the beginning.

Retention period

The Data is processed and stored for the time required by the purposes for which it was collected. Therefore:

The Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of that contract is completed.

The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest has been satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be required to retain the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, once this period has expired, the right of access, deletion, rectification, and the right to data portability can no longer be exercised.

User Rights

Users may exercise certain rights with regard to the Data processed by the Controller. In particular, the User has the right to:

withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously given.

object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are indicated in the section below.

access their Data. The User has the right to obtain information about the Data processed by the Owner, about certain aspects of the processing, and to receive a copy of the Data processed.

verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.

obtain the restriction of processing. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than their storage.

obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Controller.

receive their own Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision applies when the Data is processed by automated means and the processing is based on the User's consent, on a contract to which the User is a party, or on contractual measures related thereto. lodge a complaint. The User may lodge a complaint with the data protection supervisory authority

competent personal or take legal action.

Details on the right to object

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

Users are informed that, if their Data is processed for direct marketing purposes, they may object to such processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User's rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cookie Policy

This Website uses Tracking Tools. To learn more, the User can consult the Cookie Policy.

Further information on processing

Legal defense

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for defense against abuses in the use of this Website or the related Services by the User.

The User declares to be aware that the Data Controller may be required to disclose the Data by order of public authorities.

Specific information

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

System log and maintenance

For purposes related to operation and maintenance, this Website and any third-party services it uses may collect system logs, that is, files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

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

Response to “Do Not Track” requests

This Website does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

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

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

Information for California consumers

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the company that manages this Website and, if applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we", "our" or "ours").

The provisions contained in this section apply to all Users who are considered consumers residing in the state of California, United States of America, pursuant to the “California Consumer Privacy Act of 2018" (such Users are hereinafter simply referred to as “you”, “your”, "you" or "your"), and, for these individuals, these provisions prevail over any other potentially divergent or conflicting provisions contained in this privacy policy.

In this part of the document, the term "personal information" is used as defined by the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

This section summarizes the categories of personal information that we have collected, disclosed, or "sold" under the CCPA and the related purposes of processing. You can find detailed information about these activities in the section called "Details on the Processing of Personal Data" in this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: .

We will not collect additional categories of personal information without first providing you with a new notice.

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

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

For example, you provide us directly with your personal information when you submit requests through any form on this Website. In addition, you provide us indirectly with personal information when you browse this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in relation to the provision of the Service or the operation of this Website and its features.

How we use the information collected: sharing and communicating your personal information with third parties for operational purposes.

We may disclose your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with such third parties that obliges the recipient of your personal information to keep such information confidential and not to use it for purposes other than those necessary for the execution of the contract.

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

For further information on the purposes of processing, we invite you to consult the relevant section of this document.

No sale of your personal information

In the last 12 months we have not sold any of your personal information.

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

We may use your personal information to enable the proper functioning of this Website and its features (“operational purposes”). In such cases, your personal information will be processed in a manner that is appropriate and proportionate to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the section “Details on the processing of Personal Data” within the

this document), as well as to comply with the law and defend our rights before the competent authorities when our rights or interests are threatened or when we suffer harm.

We will not use your personal information for different, unrelated, or incompatible purposes without first providing you with a new notice.

Your privacy rights in California and how to exercise them

Right to knowledge and portability

You have the right to know the following:

the categories of personal information we collect about you and the sources of such information, the purposes for which we use your personal information, and with whom we share it;

in the event of sale or disclosure of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will inform you:

for the sale, the categories of personal information disclosed to each category of recipients; and

for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

The above information will be limited to personal information collected or used in the last 12 months.

If our response is provided electronically, the information contained therein will be "portable", meaning delivered in a compatible format so that you can transmit the information to other entities without hindrance – provided that this is technically feasible.

Right to request the deletion of your personal information

You have the right to request the deletion of any of your personal information, subject to exceptions provided by law (such as, by way of example and not limitation, in cases where the information is used to identify and fix errors on this Website, to detect security incidents, for the purpose of protection against fraudulent or illegal activities, to exercise certain rights, etc.).

If no exception provided by law applies, following the exercise of your right, we will delete your personal information and ask our providers to do the same.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request by contacting us through the contact details provided in this document.

In order to respond to your request, we need to be able to identify you. For this reason, you can exercise the above rights only by submitting a verifiable request that must:

provide sufficient information that allows us to reasonably verify that you are the person to whom the personal information we have collected relates or an authorized representative;

describe your request with a level of detail sufficient for us to understand, evaluate, and respond correctly to what you are asking.

We will not respond to any request if we are unable to verify your identity and, therefore, confirm that the information we hold actually refers to you.

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

If you are an adult, you can make a verifiable request on behalf of someone under your parental authority. You can submit a maximum of 2 requests within a 12-month period.

How and within what timeframe we will handle your request

Within 10 days we will confirm that we have received your request and provide you with information on how we will process it.

We will respond to your request within 45 days of receiving it. If we need more time, we will explain the reason and let you know how much additional time we need. A

for this purpose, please note that we may take up to 90 days to fulfill your request.

Our communications will concern the previous 12-month period. If we deny your request, we will explain the reason for the refusal.

We will not charge any fee to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or deny the request. In either case, we will inform you of our decisions and explain the reasons.

Information for Users residing in Brazil

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Website and, if applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we", "our" or "ours").

The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the "Lei Geral de Proteção de Dados" (such Users are hereinafter simply referred to as "you," "your," "yours," or "your own"). For such Users, these provisions prevail over any other provision that may differ or conflict contained in this privacy policy.

In this part of the document, the term "personal information" is used as defined by the Lei Geral de Proteção de Dados (LGPD).

Legal bases under which we process your personal information

We process your personal information exclusively when there is one of the legal bases for such processing. The legal bases are as follows:

your consent to the processing activities in question; the fulfillment of legal obligations that we are required to meet;

the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;

studies conducted by research bodies, preferably carried out on anonymized personal information; the execution of a contract and related pre-contractual obligations, if you are a party to such contract;

the exercise of our rights in court, in administrative procedures or in arbitrations; the defense or physical safety of yourself or a third party;

the protection of health - in the context of procedures implemented by entities or professionals in the healthcare sector;

our legitimate interest, provided that your fundamental rights and freedoms do not override such interests; and

the protection of credit.

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

Categories of personal information processed

To find out which categories of personal information are processed, you can refer to the section “Details on the processing of Personal Data” in this document.

Why we process your personal information

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

Your privacy rights in Brazil, how to submit a request and how it will be handled by us

Your privacy rights in Brazil

You have the right to:

obtain confirmation of the existence of processing activities concerning your personal information; access your personal information;

obtain the rectification of your incomplete, inaccurate or outdated personal information; obtain the anonymization, blocking or deletion of unnecessary personal information or

excessive, or of that information which is processed in contrast to the provisions of the LGPD; obtain information regarding the possibility of giving or refusing your consent and the related consequences;

obtain information regarding the third parties with whom we share your personal information; obtain, upon your explicit request, the portability of your personal information (with the exception of anonymized information) to other providers of products or services, provided that our trade and industrial secrets are safeguarded;

obtain the deletion of personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD applies;

revoke your consent at any time;

file a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection organization;

to object to processing activities in cases where such processing is not carried out in accordance with legal provisions;

request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; and

request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes regarding your personal information. These include decisions to outline your personal, professional, consumer or creditor profile, or other aspects of your personality.

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

How to submit a request

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

How and in what time frame we will handle your request

We will do our best to respond to your request as soon as possible.

In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons that prevent us from immediately fulfilling or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the individual or legal entity to whom you should address your requests.

In the event that you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.

You will also need to let us know if you want an immediate response, in which case you will receive a simplified answer, or if you need a complete information notice.

In this case, we will respond within 15 days from the time of your request, providing you with all information regarding the origin of your personal information, confirmation or otherwise of the existence of personal information concerning you, all the criteria used for processing and the purposes of such processing, while safeguarding our trade and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization, or blocking of personal information, we will ensure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn fulfill your request - except in cases where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between intelligence services, investigative bodies and criminal procedure authorities, as provided for by the instruments made available by international law;

when the transfer is necessary to protect your life or physical safety or that of third parties; when the transfer is authorized by the ANPD;

when the transfer derives from an obligation undertaken in the context of an international cooperation agreement;

when the transfer is necessary for the exercise of public order or for the performance of a public service;

when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in judicial, administrative, or arbitration proceedings.

Definitions and legal references

Personal Data (or Data)

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

Usage Data

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

User

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

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Controller)

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

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool by which Users' Personal Data is collected and processed.

Service

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

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Legal references

This privacy notice is drafted on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies exclusively to this Website. Last modified: November 9, 2022

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In order to receive information about your Personal Data, the purposes and the parties the Data is shared

with, contact the Owner.

For more information and to understand your rights, you can also view the complete version of this privacy policy here : https://www.iubenda.com/privacy-policy/51001203

Owner and Data Controller

Italy Lift srl

Via Sardegna 1, 65010 Moscufo (PE) Italy

Owner contact email: info@italylift.com

Types of Data collected

The owner does not provide a list of Personal Data types collected.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when

using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data

may make it impossible for this Website to provide its services. In cases where this Website specifically

states that some Data is not mandatory, Users are free not to communicate this Data without consequences

to the availability or the functioning of the Service.

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

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used

by this Website serves the purpose of providing the Service required by the User, in addition to any other

purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website

and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or

unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational

procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the

Data may be accessible to certain types of persons in charge, involved with the operation of this Website

(administration, sales, marketing, legal, system administration) or external parties (such as third-party

technical service providers, mail carriers, hosting providers, IT companies, communications agencies)

appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be

requested from the Owner at any time.

Legal basis of processing

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

Users have given their consent for one or more specific purposes. Note: Under some legislations the

Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”),

without having to rely on consent or any other of the following legal bases. This, however, does not

apply, whenever the processing of Personal Data is subject to European data protection law;

provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual

obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official

authority vested in the Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third

party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in

particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in

the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other

than their own. To find out more about the place of processing of such transferred Data, Users can check the

section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European

Union or to any international organization governed by public international law or set up by two or more

countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document

or inquire with the Owner using the information provided in the contact section.

Retention time

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

for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and

the User shall be retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as

needed to fulfill such purposes. Users may find specific information regarding the legitimate interests

pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent

to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to

retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation

or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to

erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the

retention period.

The rights of Users

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

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

Withdraw their consent at any time. Users have the right to withdraw consent where they have

previously given their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if

the processing is carried out on a legal basis other than consent. Further details are provided in the

dedicated section below.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain

disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing

processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it

to be updated or corrected.

Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict

the processing of their Data. In this case, the Owner will not process their Data for any purpose other

than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right, under certain

circumstances, to obtain the erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive

their Data in a structured, commonly used and machine readable format and, if technically feasible, to

have it transmitted to another controller without any hindrance. This provision is applicable provided

that the Data is processed by automated means and that the processing is based on the User's consent,

on a contract which the User is part of or on pre-contractual obligations thereof.

Lodge a complaint. Users have the right to bring a claim before their competent data protection

authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the

Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such

processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they

can object to that processing at any time without providing any justification. To learn, whether the Owner is

processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this

document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in

this document. These requests can be exercised free of charge and will be addressed by the Owner as early

as possible and always within one month.

Cookie Policy

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

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to

possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of

public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with

additional and contextual information concerning particular Services or the collection and processing of

Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that

record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this

purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at

any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read

their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this

page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to

Users via any contact information available to the Owner. It is strongly recommended to check this page

often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall

collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the

subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of

California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are

referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede

any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer

Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold

and the purposes thereof. You can read about these activities in detail in the section titled

“Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: .

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

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

We collect the above mentioned categories of personal information, either directly or indirectly, from you

when you use this Website.

For example, you directly provide your personal information when you submit requests via any forms on this

Website. You also provide personal information indirectly when you navigate this Website, as personal

information about you is automatically observed and collected. Finally, we may collect your personal

information from third parties that work with us in connection with the Service or with the functioning of this

Website and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with

third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this

case, we enter a written agreement with such third party that requires the recipient to both keep the

personal information confidential and not use it for any purpose(s) other than those necessary for the

performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do

so, in order to provide you with our Service.

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

No sale of your personal information

In the past 12 months we have not sold any of your personal information.

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

We may use your personal information to allow the operational functioning of this Website and features

thereof (“business purposes”). In such cases, your personal information will be processed in a fashion

necessary and proportionate to the business purpose for which it was collected, and strictly within the limits

of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated

within the section “Detailed information on the processing of Personal Data” within this document), as well

as for complying with the law and defending our rights before the competent authorities where our rights

and interests are threatened or we suffer an actual damage.

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

you.

Your California privacy rights and how to exercise them

The right to know and to portability

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

the categories and sources of the personal information that we collect about you, the purposes for

which we use your information and with whom such information is shared;

in case of sale of personal information or disclosure for a business purpose, two separate lists where we

disclose:

for sales, the personal information categories purchased by each category of recipient; and

for disclosures for a business purpose, the personal information categories obtained by each

category of recipient.

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

months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an

easily usable format to enable you to transmit the information to another entity without hindrance – provided

that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth

by the law (such as, including but not limited to, where the information is used to identify and repair errors

on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise

certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and

direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via

the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise

the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we

collected personal information or an authorized representative;

describe your request with sufficient detail that allows us to properly understand, evaluate, and respond

to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal

information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California

Secretary of State to act on your behalf.

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

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

How and when we are expected to handle your request

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

process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to

you the reasons why, and how much more time we need. In this regard, please note that we may take up to

90 days to fulfill your request.

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

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

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly

unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In

either case, we will communicate our choices and explain the reasons behind it.

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the

subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de

Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these

provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção

de Dados (LGPD).

The grounds on which we process your personal information

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

as follows:

your consent to the relevant processing activities;

compliance with a legal or regulatory obligation that lies with us;

the carrying out of public policies provided in laws or regulations or based on contracts, agreements and

similar legal instruments;

studies conducted by research entities, preferably carried out on anonymized personal information;

the carrying out of a contract and its preliminary procedures, in cases where you are a party to said

contract;

the exercising of our rights in judicial, administrative or arbitration procedures;

protection or physical safety of yourself or a third party;

the protection of health – in procedures carried out by health entities or professionals;

our legitimate interests, provided that your fundamental rights and liberties do not prevail over such

interests; and

credit protection.

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

this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled

“Detailed information on the processing of Personal Data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information

on the processing of Personal Data” and “The purposes of processing” within this document.

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

requests

Your Brazilian privacy rights

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;

access to your personal information;

have incomplete, inaccurate or outdated personal information rectified;

obtain the anonymization, blocking or elimination of your unnecessary or excessive personal

information, or of information that is not being processed in compliance with the LGPD;

obtain information on the possibility to provide or deny your consent and the consequences thereof;

obtain information about the third parties with whom we share your personal information;

obtain, upon your express request, the portability of your personal information (except for anonymized

information) to another service or product provider, provided that our commercial and industrial secrets

are safeguarded;

obtain the deletion of your personal information being processed if the processing was based upon your

consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

revoke your consent at any time;

lodge a complaint related to your personal information with the ANPD (the National Data Protection

Authority) or with consumer protection bodies;

oppose a processing activity in cases where the processing is not carried out in compliance with the

provisions of the law;

request clear and adequate information regarding the criteria and procedures used for an automated

decision; and

request the review of decisions made solely on the basis of the automated processing of your personal

information, which affect your interests. These include decisions to define your personal, professional,

consumer and credit profile, or aspects of your personality.

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

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the

contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or

legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases

where we are not processing your personal information, we will indicate to you the physical or legal person to

whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please

make sure that you specify whether you’d like your personal information to be delivered in electronic or

printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we

will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the

information on the origin of your personal information, confirmation on whether or not records exist, any

criteria used for the processing and the purposes of the processing, while safeguarding our commercial and

industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking

request, we will make sure to immediately communicate your request to other parties with whom we have

shared your personal information in order to enable such third parties to also comply with your request –

except in cases where such communication is proven impossible or involves disproportionate effort on our

side.

Transfer of personal information outside of Brazil permitted by the law

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

when the transfer is necessary for international legal cooperation between public intelligence,

investigation and prosecution bodies, according to the legal means provided by the international law;

when the transfer is necessary to protect your life or physical security or those of a third party;

when the transfer is authorized by the ANPD;

when the transfer results from a commitment undertaken in an international cooperation agreement;

when the transfer is necessary for the execution of a public policy or legal attribution of public service;

when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a

contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial,

administrative or arbitration procedures.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal

identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website),

which can include: the IP addresses or domain names of the computers utilized by the Users who use this

Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to

submit the request to the server, the size of the file received in response, the numerical code indicating the

status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the

browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent

on each page within the Application) and the details about the path followed within the Application with

special reference to the sequence of pages visited, and other parameters about the device operating system

and/or the User's IT environment.

User

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

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf

of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others,

determines the purposes and means of the processing of Personal Data, including the security measures

concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the

Owner of this Website.

This Website (or this Application)

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

Service

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

site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all

current member states to the European Union and the European Economic Area.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of

Regulation (EU) 2016/679 (General Data Protection Regulation).

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

Latest update: November 09, 2022