Privacy Policy

This Application collects some Personal Data from its Users.

Owner and Data Controller

App Bards

Owner contact email: appbards@gmail.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Camera permission; Precise location permission (non-continuous); Approximate location permission (non-continuous); Microphone permission; Storage permission; first name; email address; last name; profile picture.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific 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 Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

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

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

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

Place

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

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

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 to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Advertising, Analytics, Handling payments, Location-based interactions, Device permissions for Personal Data access, Access to third-party accounts, Backup saving and management, Contacting the User, Interaction with external social networks and platforms, Platform services and hosting, Registration and authentication, Hosting and backend infrastructure, Managing contacts and sending messages, Infrastructure monitoring and Content performance and features testing (A/B testing).

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

Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.

The exact procedure for controlling app permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of this Application. If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User's device, including the changing of entries.

Microphone permission

Used for accessing and recording microphone audio from the User's device.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

SMS permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows this Application to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.

Google Drive account access (Google Inc.)

This service allows this Application to connect with the User's account on Google Drive, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy.

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

This processing constitutes:

a sale according to the CCPA, CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those

detected outside this Application. For more information, please check the privacy policies of the relevant services. Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

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

Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

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

This processing constitutes:

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

Android Advertiser ID

We use Android Advertiser identifier only for advertising.

The advertising identifier is not connected to personally identifiable information or associated with any persistent device identifier.

This processing constitutes:

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

Analytics

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

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.

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

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

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

This processing constitutes:

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

Backup saving and management

This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.

Backup on Google Drive (Google Inc.)

Google Drive is a service to save and manage backups provided by Google Inc.

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

Place of processing: US – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Contacting the User

Contact form (this Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: email address; first name.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.

Firebase Remote Config

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

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

Device permissions for Personal Data access

This Application requests certain permissions from Users that allow it to access the User's device Data as described below.

Device permissions for Personal Data access (this Application)

This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

Personal Data processed: Approximate location permission (non-continuous); Camera permission; Microphone permission; Precise location permission (non-continuous); Storage permission.

Category of personal information collected according to the CCPA: internet or other electronic network activity information; geolocation data.

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Handling payments

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Google Pay (Google Inc.)

Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

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

Place of processing: US – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

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

Place of processing: US – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Payments processed via the Google Play Store

This Application uses a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: payment data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: commercial information.

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Payments processed via the Apple App Store (Apple Inc.)

This Application uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data processed: payment data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: commercial information.

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Firestore

Firebase Cloud Firestore is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Firebase Cloud Storage

Firebase Cloud Storage is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Firebase Realtime Database

Firebase Realtime Database is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Infrastructure monitoring

This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

Firebase Performance Monitoring

Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Location-based interactions

Non-continuous geolocation (this Application)

This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data processed: geographic position.

Category of personal information collected according to the CCPA: geolocation data.

This processing constitutes:

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

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 to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Firebase Notifications

Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

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

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

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

Firebase Cloud Messaging

Firebase Cloud Messaging is a message sending service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments. Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

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

Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Play Store

This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to

manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Apple App Store (Apple Inc.)

This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc. By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of this Application. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

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

This processing constitutes:

a sale according to the CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Firebase Authentication

Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

Personal Data processed: email address; first name; last name; profile picture.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; audio, electronic, visual, thermal, olfactory, or similar information.

This processing constitutes:

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

Further information about the processing of Personal Data

Unique device identification

This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

User identification via a universally unique identifier (UUID)

This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Push notifications

This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of this Application.

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 precontractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

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

Further information about retention time

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to 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 to rectification 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 their consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the

erasure of their Data from the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
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 for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

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

vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users

may object to such processing by providing a ground related to their particular situation to

justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing

any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible 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 conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information 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 Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
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

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 is provided by the entity 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”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information 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 legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.

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

Categories of personal information processed

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

Why we process your personal information

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

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

requests

Your Brazilian privacy rights

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

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

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to

whom you should address your requests, if we are in the position to do so. In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

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

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets. In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

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

when the transfer is necessary for international legal cooperation between public intelligence,
investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial,
administrative or arbitration procedures.

Additional information about Data collection and processing

Legal action The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application 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 Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (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 see the 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 possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device

operating system and/or the User's IT environment.

User

The individual using this Application 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, as described in this privacy policy.

Data Controller (or Owner)

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

This Application

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

Service

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

European Union (or EU)

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

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 Application, if not stated otherwise within this document.

Latest update: December 08, 2023