Privacy Policy
Privacy Policy of www.letztitan.lu
This Website collects some Personal Data from its Users.
Owner and Data Controller
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: first name; last name;company name; country; email address; city; Trackers; Usage Data; number of Users; session statistics; payment info; billingaddress; purchase history; phone number; answers to questions; clicks; keypress events; motion sensor events; mousemovements; scroll position; touch events; physical address; website; geographic position; precise location; coarse location;password; picture; date of birth; username; VAT Number; ZIP/Postal code; profile picture; User ID; various types of Data; state;shipping address; house number; data relating to the point of sale.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or byspecific explanation texts displayed prior to the Data collection.Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make itimpossible for this Website to provide its services. In cases where this Website specifically states that some Data is notmandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of theService.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 Websiteserves the purpose of providing the Service required by the User, in addition to any other purposes described in the presentdocument and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthoriseddestruction of the Data.The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modesstrictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types ofpersons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) orexternal parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communicationsagencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from theOwner at any time.
Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing arelocated.Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. Tofind out more about the place of processing of such transferred Data, Users can check the section containing details about theprocessing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond toenforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulentactivity, as well as the following: Contacting the User, Analytics, Handling payments, Managing contacts and sending messages,Registration and authentication, Displaying content from external platforms, Spam and bots protection, Location-basedinteractions, Tag Management, Advertising, Interaction with external social networks and platforms, Content commenting andRegistration and authentication provided directly by this Website.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed informationon the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications aredisplayed in the form of banners and other advertisements on this Website, possibly based on User interests. This does not meanthat all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listedbelow may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to theUser’s interests and behaviour, including those detected outside this Website. For more information, please check the privacypolicies of the relevant services. Services of this kind usually allow Users to opt out of such tracking. Users may learn how to optout of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Google Ads conversion tracking
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending onhow the Owner manages the Data processing, that connects data from the Google Ads advertising network with actionsperformed on this Website.
In order to understand Google’s use of Data, consult their partner policy and their Business Data page.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Google Ads enhanced conversions
Google Ads enhanced conversions is an advertising service provided by Google LLC or by Google Ireland Limited, dependingon how the Owner manages the Data processing, that allows the Owner to send hashed first-party conversion Data to Google inorder to improve conversion measurements.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of Userbehaviour.
Google Analytics 4
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how theOwner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Website,to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualizeand personalize the ads of its own advertising network. In Google Analytics 4, IP addresses are used at collection time and thendiscarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google’s use of Data, consult their partner policy and their Business Data page.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
WordPress Stats (Automattic Inc.)
WordPress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests forinformation, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: city; company name; country; email address; first name; last name.
Category of Personal Information collected according to CCPA: identifiers; commercial information.
Phone contact (this Website)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, aswell as for fulfilling support requests.
Personal Data processed: phone number.
Category of Personal Information collected according to CCPA: identifiers.
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who mayreceive email messages containing information of commercial or promotional nature concerning this Website. Your email addressmight also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: city; company name; country; email address; first name; last name; phone number; physical address;website.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information.
Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Website. Depending on thesettings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Dataprovided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the contentof their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic datafor the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (this Website)
This Website has its own internal content comment system.
Personal Data processed: email address; first name; last name; Usage Data; website.
Category of Personal Information collected according to CCPA: identifiers; internet information.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interactwith them. Such services are often referred to as widgets, which are small elements placed on a website or app. They providespecific information or perform a particular function and often allow for user interaction. This type of service might still collectweb traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts
Google Fonts is a typeface visualisation service provided by Google LLC or by Google Ireland Limited, depending on how theOwner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Gravatar
Gravatar is an image visualisation service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on howthe Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages. Please note thatif Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if thecommenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
Google Maps widget
Google Maps is a maps visualisation service provided by Google LLC or by Google Ireland Limited, depending on how theOwner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Instagram widget
Instagram is an image visualisation service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending onhow the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Handling payments
Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via externalpayment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details andpersonal information directly to such payment service providers. This Website isn’t involved in the collection and processing ofsuch information: instead, it will only receive a notification by the relevant payment service provider as to whether payment hasbeen successfully completed.
Stripe ( Stripe Technology Europe Ltd)
Stripe is a payment service provided by Stripe Technology Europe Ltd.
Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; Trackers; varioustypes of Data as specified in the privacy policy of the service.
Place of processing: European Union – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.The interaction and information obtained through this Website are always subject to the User’s privacy settings for each socialnetwork. This type of service might still collect traffic data for the pages where the service is installed, even when Users do notuse it. It is recommended to log out from the respective services in order to make sure that the processed data on this Websiteisn’t being connected back to the User’s profile.
X Post button and social widgets (X Corp.)
The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Facebook Like button and social widgets
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided byMeta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
Location-based interactions
Geolocation (this Website)
This Website may collect, use, and share User location Data in order to provide location-based services. Most browsers anddevices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location datamay be tracked by this Website.
Personal Data processed: coarse location; geographic position; precise location.
Category of Personal Information collected according to CCPA: geolocation data.
Non-continuous geolocation (this Website)
This Website may collect, use, and share User location Data in order to provide location-based services. Most browsers anddevices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location datamay be tracked by this Website. The geographic location of the User is determined in a manner that isn’t continuous, either at thespecific request of the User or when the User doesn’t point out its current location in the appropriate field and allows theapplication to detect the position automatically.
Personal Data processed: coarse location; geographic position; precise location.
Category of Personal Information collected according to CCPA: geolocation data.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information tocommunicate with the User. These services may also collect data concerning the date and time when the message was viewed bythe User, as well as when the User interacted with it, such as by clicking on links included in the message.
BulkSMS (this Website)
BulkSMS is a phone numbers management and communication service provided by – Celerity Europe AG; – Celerity SystemsLtd; – Celerity Messaging Ltd.
Personal Data processed: phone number.
Place of processing: various places depending on the company that provides the service – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
Registration and authentication
By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. Dependingon what is described below, third parties may provide registration and authentication services. In this case, this Website will beable to access some Data, stored by these third-party services, for registration or identification purposes. Some of the serviceslisted below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the descriptionof each service.
Facebook Authentication
Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta PlatformsIreland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: identifiers; internet information.
Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process,Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; password; picture; Trackers; various types of Data as specified inthe privacy policy of the service.
Place of processing: United States – Privacy Policy; European Union – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information; sensorial information.
Direct registration and profiling (this Website)
By registering or authenticating directly through this Website, Users allow this Website to identify them and give them access todedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profilingpurposes; to find out more, Users can contact the Owner using the contact details provided in this document.
Personal Data processed: billing address; company name; country; data relating to the point of sale; date of birth; email address;first name; geographic position; house number; last name; password; phone number; physical address; profile picture; shippingaddress; state; User ID; username; VAT Number; website; ZIP/Postal code.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information;geolocation data; sensorial information.
Registration and authentication provided directly by this Website
By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. ThePersonal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessaryfor the provision of the service requested by the Users.
Direct registration (this Website)
The User registers by filling out the registration form and providing the Personal Data directly to this Website.
Personal Data processed: billing address; city; company name; country; date of birth; email address; first name; last name; profilepicture; Usage Data; User ID; username; various types of Data; VAT Number; website; ZIP/Postal code.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information;sensorial information.
Spam and bots protection
This type of service analyses the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filteringit from unwanted parts of traffic, messages and content that are recognised as spam or protecting it from malicious bots activities.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on howthe Owner manages the Data processing. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google’s use of Data, consult their partner policy and their Business Data page.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position;touch events; Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information; inferred information.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralised fashion. This results inthe Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how theOwner manages the Data processing.
In order to understand Google’s use of Data, consult their partner policy and their Business Data page.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how togenerally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
localStorage
localStorage allows this Website to store and access data right in the User’s browser with no expiration date.
sessionStorage
sessionStorage allows this Website to store and access data right in the User’s browser. Data in sessionStorage is deletedautomatically when the session ends (in other words, when the browser tab is closed).
Browser Fingerprinting
Browser Fingerprinting creates an identifier based on a device’s unique combination of characteristics (e.g. IP address, HTTPheader, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User’sbrowsing behaviour across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.
Preference Cookies
Preference Cookies store the User preferences detected on this Website in the local domain such as, for example, their timezoneand region.
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or anyother means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
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.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligationsthereof;
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 theOwner;
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 whetherthe provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about 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 beretained 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 fulfillsuch purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within therelevant 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 periodwhenever required to fulfil 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 torectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the 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.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing iscarried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regardingcertain 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 orcorrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Ownerwill not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from theOwner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in astructured, commonly used and machine readable format and, if technically feasible, to have it transmitted to anothercontroller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to anyinternational organisation governed by public international law or set up by two or more countries, such as the UN, and about thesecurity 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 enquire with theOwner using the information provided in the contact section.
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 forthe purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a groundrelated 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 tothat processing at any time, free of charge and without providing any justification. Where the User objects to processingfor direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether theOwner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of thisdocument.
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. Suchrequests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Userswith the information required by law. Any rectification or erasure of Personal Data or restriction of processing will becommunicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this provesimpossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflictinginformation contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personaldata, if any, the retention period and further information about Personal Data can be found in the section titled “Detailedinformation on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of PersonalData be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties beprohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
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. Suchrequests are free of charge and will be answered by the Owner as early as possible, providing Users with the information requiredby law.
Further information for Users in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and isprovided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of thissection referred to collectively as “we”, “us”, “our”).This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the “LeiGeral de Proteção de Dados” (the “LGPD”), and for such Users, it supersedes any other possibly divergent or conflictinginformation contained in the privacy policy.This part of the document uses the term “personal information“ as it is defined in the 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 legalinstruments;
studies conducted by research entities, preferably carried out on anonymised 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 onthe 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 ofPersonal 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 ofinformation 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 anonymised information) toanother 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 oneor 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 withconsumer 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, whichaffect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspectsof 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 providedin 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 thatprevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing yourpersonal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are inthe position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specifywhether 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 asimplified 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 purposesof 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 sureto immediately communicate your request to other parties with whom we have shared your personal information in order toenable such third parties to also comply with your request – except in cases where such communication is proven impossible orinvolves 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 prosecutionbodies, 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 authorised 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 orpreliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitrationprocedures.
Further information for Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and isprovided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes ofthis section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”),who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information (and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected ordisclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyonewho is not a California resident to get a general idea of what types of Personal Information are collected.
Identifiers
Commercial information
Internet or other electronic network activity information
Inferences drawn from other personal information
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
ℹ️You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My SensitivePersonal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing ofPersonal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatiblewith the purposes originally disclosed, without your consent.
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 thisWebsite.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You alsoprovide Personal Information indirectly when you navigate this Website, as Personal Information about you is automaticallyobserved and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with thefunctioning of this Website and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, youhave:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether ornot we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccuratePersonal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of yourPersonal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable andusable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercisingyour privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which isnecessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note thatcertain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive PersonalInformation is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado,Connecticut, Texas and Oregon, you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtheranceof decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information.Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection andprocessing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested bythe consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptionsoutlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive PersonalInformation is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided inthis document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify youridentity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an accountwith us to submit your request. We will use any Personal Information collected from you in connection with the verification ofyour request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary forpurposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also usethe privacy choices link provided on this Website.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacycontrol, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in africtionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should weneed more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you maythen contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in allother cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on therequest. In either case, we will communicate our choices and explain the reasons behind them.
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 actionarising 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 contextualinformation 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 withthis Website (System logs) or 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 seethe contact information at the beginning of this document.
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 possiblywithin this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact informationavailable to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed atthe bottom.Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consentfrom the User, where required.
Definitions and legal references
Personal Data (or Data) / Personal Information (or Information)
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.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information consideredsensitive according to the applicable privacy law.
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 utilised by the Users who use this Website, the URI addresses (UniformResource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received inresponse, 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 utilised by the User, the various time details per visit (e.g., the time spent oneach page within the Application) and the details about the path followed within the Application with special reference to thesequence 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 Processor)
The natural or legal person, public authority, agency or other 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 or other body which, alone or jointly with others, determines the purposesand 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.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuableconsideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with aservice provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale ofyour Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwisecommunicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to a thirdparty for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactionsbetween a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money isexchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a serviceprovider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharingof your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on PersonalInformation obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predictsuch consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states tothe European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.
Tracker
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Website, if not stated otherwise within this document.
Latest update: 1 August 2024