Privacy Policy

 

GDPR Privacy Policy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
● Consent: You have given Your consent for processing Personal Data for one or more specific
purposes.
● Performance of a contract: Provision of Personal Data is necessary for the performance of an
agreement with You and/or for any pre-contractual obligations thereof.
● Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to
which the Company is subject.
● Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of
another natural person.
● Public interests: Processing Personal Data is related to a task that is carried out in the public
interest or in the exercise of official authority vested in the Company.
● Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate
interests pursued by the Company.
In any case, the Company 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.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can
exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
● Request access to Your Personal Data. The right to access, update or delete the information We
have on You. Whenever made possible, you can access, update or request deletion of Your
Personal Data directly within Your account settings section. If you are unable to perform these
actions yourself, please contact Us to assist You. This also enables You to receive a copy of the
Personal Data We hold about You.
● Request correction of the Personal Data that We hold about You. You have the right to have
any incomplete or inaccurate information We hold about You corrected.
● Object to processing of Your Personal Data. This right exists where We are relying on a
legitimate interest as the legal basis for Our processing and there is something about Your particular
situation, which makes You want to object to our processing of Your Personal Data on this ground.
You also have the right to object where We are processing Your Personal Data for direct marketing
purposes.
● Request erasure of Your Personal Data. You have the right to ask Us to delete or remove
Personal Data when there is no good reason for Us to continue processing it.
● Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have
chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note
that this right only applies to automated information which You initially provided consent for Us to
use or where We used the information to perform a contract with You.

● Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data.
If You withdraw Your consent, We may not be able to provide You with access to certain specific
functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please
note that we may ask You to verify Your identity before responding to such requests. If You make a request,
We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal
Data. For more information, if You are in the European Economic Area (EEA), please contact Your local
data protection authority in the EEA.
CCPA Privacy Policy
This privacy notice section for California residents supplements the information contained in Our Privacy
Policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with,
or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a
list of categories of personal information which we may collect or may have been collected from California
residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA.
This does not mean that all examples of that category of personal information were in fact collected by Us,
but reflects our good faith belief to the best of our knowledge that some of that information from the
applicable category may be and may have been collected. For example, certain categories of personal
information would only be collected if You provided such personal information directly to Us.
● Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, driver’s license number, passport number, or other
similar identifiers.
Collected: Yes.
● Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description,
address, telephone number, passport number, driver’s license or state identification card number,
insurance policy number, education, employment, employment history, bank account number, credit
card number, debit card number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category may overlap with other
categories.

Collected: Yes.
● Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or
creed, marital status, medical condition, physical or mental disability, sex (including gender, gender
identity, gender expression, pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
● Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: Yes.
● Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used
to extract a template or other identifier or identifying information, such as, fingerprints, faceprints,
and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or
exercise data.
Collected: No.
● Category F: Internet or other similar network activity.
Examples: Interaction with our Service or advertisement.
Collected: Yes.
● Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
● Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
● Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.

● Category J: Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or
party acting on its behalf, such as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary records.
Collected: No.
● Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal information does not include:
● Publicly available information from government records
● Deidentified or aggregated consumer information
● Information excluded from the CCPA’s scope, such as:
● Health or medical information covered by the Health Insurance Portability and Accountability Act of
1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial
data
● Personal Information covered by certain sector-specific privacy laws, including the Fair Credit
Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information
Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
● Directly from You. For example, from the forms You complete on our Service, preferences You
express or provide through our Service, or from Your purchases on our Service.
● Indirectly from You. For example, from observing Your activity on our Service.
● Automatically from You. For example, through cookies We or our Service Providers set on Your
Device as You navigate through our Service.
● From Service Providers. For example, third-party vendors to monitor and analyze the use of our
Service, third-party vendors for payment processing, or other third-party vendors that We use to
provide the Service to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for “business purposes” or “commercial purposes”
(as defined under the CCPA), which may include the following examples:
● To operate our Service and provide You with our Service.
● To provide You with support and to respond to Your inquiries, including to investigate and address
Your concerns and monitor and improve our Service.