Privacy Policy of www.boatiful-lake.com
This Website collects some Personal Data from its Users.
This document contains a section dedicated to California consumers and their privacy rights.
This document contains a section dedicated to Virginia consumers and their privacy rights.
This document contains a section dedicated to Users residing in Brazil and their privacy rights.
This document can be printed using the print command in the settings of any browser.
Data Controller
Boatiful Lake Srl, Via Adamo del Pero 38, 22100 Como (CO), Italy. Owner’s email address: info@boatiful-lake.com
Types of Data collected
Among the Personal Data collected by this Website, independently or through third parties, there are: Tracking Tool; Usage data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); device information; geographic region; number of Users; number of sessions; session duration; opening the Application; Application updates; launches; operating systems; e-mail. Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts 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 communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation. Users who have doubts about which Data is mandatory are encouraged to contact the Owner. Any 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, has the purpose of providing the Service requested by the User, as well as to the additional 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 he or she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.
Method and place of processing of the collected data
Treatment methods
The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.
Legal basis of the processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
· the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner 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 this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
· the processing is necessary for the execution of a contract with the User and/or the execution 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 execution of a task of public interest or for the exercise of public powers vested in the Data Controller;
· the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.
Place
The Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner. The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. The User can verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the opening.
Retention period
The Data is processed and stored for the time required by the purposes for which it was collected. Therefore:
Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
Purpose of the Processing of Collected Data
The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Statistics, Displaying content from external platforms and Contacting the User. To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
· Contacting the User: By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or of any other nature indicated by the form header. Personal Data processed: email. Category of Personal Information Collected Under the CCPA: Identifiers. This type of processing constitutes: a sale under the VCDPA.
· Statistics: The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.
· Google Analytics: Google Analytics is a web analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. Personal Data processed: Usage data; Tracking Tool. Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Category of personal information collected under the CCPA: Internet information. This type of processing constitutes: a sale under the CCPA and VCDPA.
· Google Analytics for Firebase: Google Analytics for Firebase, or Firebase Analytics, is an analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data. For an understanding of the use of data on Google’s part, please see our partner policies by Google. Firebase Analytics may share Data with other services provided by Firebase including, for example, Crash Reporting, Authentication, Remote Config or Notifications. The user can consult this privacy policy for a detailed description of the other tools used by the Owner. To allow Firebase Analytics to function, this Website uses some identifiers for mobile devices or technologies similar to cookies. You can opt-out of some Firebase features through your mobile device settings. For example, you can change the advertising settings available on your mobile phone, or follow the instructions applicable to Firebase that may be present in this privacy policy. Personal Data processed: Application updates; opening the Application; Usage data; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); device information; launches; number of sessions; number of Users; geographic region; operating systems; Tracking Tool. Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Category of Personal Information Collected Under the CCPA: Identifiers; information on the Internet; geolocation data. This type of processing constitutes: a sale under the CCPA and VCDPA.
· Google Analytics with anonymized IP: Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. This Google Analytics integration anonymizes your IP address. Anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google servers and shortened within the United States. Personal Data processed: Usage data; Tracking Tool. Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out. Category of personal information collected under the CCPA: Internet information. This type of processing constitutes: a sale under the CCPA and VCDPA.
· Viewing 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 interact with them. This type of service could still collect data on web traffic relating to the pages where the service is installed, even when users do not use it. o Font Awesome (Fonticons, Inc.): Font Awesome is a character style visualization service managed by Fonticons, Inc. that allows this Website to integrate such content within its pages. Personal Data processed: Usage data; Tracking Tool. Place of processing: United States – Privacy Policy. Category of Personal Information Collected Under the CCPA: Internet Information. This type of processing constitutes: a sale under the CCPA and VCDPA.
Learn how to opt out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users can read more about how to opt out of interest-based advertising in the appropriate section of the Cookie Policy.
Further information on the processing of Personal Data
Sale of goods and services online: The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may be those relating to the credit card, the current account used for the bank transfer or other payment instruments provided. The Payment Data collected by this Website depends on the payment system used.
User Rights
Users can exercise certain rights with reference to the Data processed by the Owner. In particular, the User has the right to:
· revoke consent at any time. The User can revoke the consent previously expressed to the processing of their Personal Data.
· object to the processing of their Data. The User can object to the processing of their Data when it occurs 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 on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
· verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
· obtain the limitation of processing. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any purpose other than their conservation.
· obtain the deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.
· receive their Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without obstacles to another owner. This provision is applicable · when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
· lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation. Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Owner 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 can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as quickly as possible, in any case within one month.
Cookie Policy
This Website uses Tracking Tools. To find out more, the User can consult the Cookie Policy.
Learn more about the data processing
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Website or related Services by the User. The User declares to be aware that the Owner may be obliged to reveal the Data by order of public authorities.
Specific information
Upon request of the User, 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 logs and maintenance
For needs related to operation and maintenance, this Website and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to “Do Not Track” requests
This Website does not support “Do Not Track” requests. To find out whether any third-party services used support them, the User is invited to consult 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, if technically and legally feasible, by sending a notification to Users through one of the extremes contact number he has. Please therefore consult this page frequently, referring to the date of last modification indicated at the bottom. If the changes affect processing whose legal basis is consent, the Owner will collect the User’s consent again, if necessary.
Information for Californian consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the “California Consumer Privacy Act of 2018” (the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).
Notice at collection
Categories of personal information collected, used, sold, or shared
In this section we summarize the categories of personal information that we’ve collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, internet information and geolocation data. We do not collect sensitive personal information. We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Website. For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA. We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA. This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like. For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA. Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing. You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request. To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document. For a simplified opt-out method you can also use the privacy choices link provided on this Website. If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here. We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
- the categories of personal information that we collect about you;
- the sources from which the personal information is collected;
- the purposes for which we use your information;
- to whom we disclose such information;
- the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
- the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
- the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months. If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes. If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority. You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request. We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort. Should we deny your request, we will explain you the reasons behind our denial. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.
Information for Virginia consumers
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, internet information and geolocation data We do not collect sensitive data. We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document. We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent. You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing. For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA. Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document. We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
- access personal data: the right to know.You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
- correct inaccurate personal data.You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
- request the deletion of your personal data.You have the right to request that we delete any of your personal data.
- obtain a copy of your personal data.We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
- opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profilingin furtherance of decisions that produce legal or similarly significant effects concerning you.
- non-discrimination.We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. For us to respond to your request, we need to know who you are. We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes. If you are an adult, you can make a request on behalf of a minor under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint. We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Information for consumers residing in Brazil
This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this Website and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “ us”, “our” or “our”). The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the “Lei Geral de Proteção de Dados” (such Users are referred to hereinafter simply as “you”, “your”, “you” or “your”). For such Users, these provisions prevail over any other possibly 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 Lei Geral de Proteção de Dados (LGPD).
Legal bases on which we process your personal information
We process your personal information only if one of the legal bases for such processing exists. The legal bases are as follows:
your consent to the processing activities in question;
compliance with legal obligations that we are required to satisfy;
· the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
studies conducted by research institutions, preferably carried out on anonymized personal information;
· the execution of a contract and the related pre-contractual obligations, if you are part of this contract;
· the exercise of our rights in court, administrative proceedings or arbitration;
· the defense or physical safety of you or a third party;
· health protection – in the context of procedures implemented by entities or professionals in the healthcare sector;
· our legitimate interests, provided that your fundamental rights and freedoms do not override 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 which categories of personal information are processed, you can refer to the “Details on the processing of Personal Data” section in this document.
Why we process your personal information
To find out why we process your personal information, please refer to the “Details on the processing of Personal Data” and “Purpose of the Processing of Collected Data” sections in this document.
Your privacy rights in Brazil, how to make a request and how we will handle it
Your privacy rights in Brazil
You have the right to:
· obtain confirmation of the existence of processing activities regarding your personal information;
· access your personal information;
· obtain rectification of your incomplete, inaccurate or out-of-date personal information;
· obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or that information which is processed in conflict with the provisions of the LGPD;
· get informed regarding the possibility of giving or refusing your consent and the related consequences;
· obtain information about the third parties with whom we share your personal information;
· obtain, upon your explicit request, the portability of your personal information (with the exception of anonymized information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
· obtain the deletion of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 LGPD apply;
· withdraw your consent at any time;
· lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
· oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;
· request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And
· request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.
You will never be discriminated against, nor will you in any way suffer any treatment that is unfavorable to you, following the exercise of your rights.
How to submit a request
You can send an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.
How and in what time we will handle your request
We will do our best to 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 communicate to you the factual or legal reasons that prevent us from immediately satisfying 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 to you the natural or legal person to whom your requests should be addressed. 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 be sure to specify whether you prefer to receive your personal information in electronic or paper format. You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require full disclosure. In the latter case, we will respond within 15 days from the time of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the processing and the purposes of such processing, while safeguarding our commercial and industrial secrets. In the event that you decide to make a request for rectification, deletion, anonymization or blocking of personal information, we will ensure that we immediately inform the other parties with whom we have shared your personal information of your request so that they can also satisfy your request – except in cases where such communication is impossible or excessively burdensome for us.
Transfer of personal information outside of Brazil where permitted by law
We may transfer your personal information outside of Brazilian territory in the following cases:
· when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedural bodies, as provided for by the tools made available by international law;
· when the transfer is necessary to defend the life or physical safety of you or third parties;
· when the transfer is authorized by the ANPD;
· when the transfer arises from an obligation assumed in the context of an international cooperation agreement;
· when the transfer is necessary for the exercise of 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 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 constitutes any information which, directly or indirectly, also in connection with any other information, including an identification number that makes a natural person identified or identifiable.
Usage Data
This is information collected automatically through this Website (also by third-party applications integrated into this Website), including: IP addresses or domain names of the computers used by the User who connects to this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc. .) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.
User
The individual who uses this Website who, unless otherwise specified, coincides with the interested party.
Interested
The natural person to whom the Personal Data refers.
Data Controller (or Manager)
The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Data Controller)
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 and the tools adopted, including security measures relating 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 through which the Personal Data of Users is collected and processed.
Service
The service provided by this Website as defined in the relevant terms (if available) 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.
Cookies
Cookies are Tracking Tools that consist of small portions of data stored within the User’s browser.
Tracking Tool
Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting – which allows Users to be tracked, for example by collecting or saving information on the User’s device.
Legal references
This privacy information is drawn up 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.
