Privacy Policy of Klaxon Mobility GmbH

Containing the Legal Information

This Website collects some Personal Data from its Users.
This document contains a section dedicated to Californian consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Klaxon Mobility GmbH
Industriestraße,1
9601 – Arnoldstein (Austria)
Owner contact email: dpo@klaxon-klick.com

Types of Data collected

Personal Data

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; gender; date of birth; phone number; VAT Number; company name; profession; address; fax number; country; state; county; email address; ZIP/Postal code; various types of Data; city; Tax ID; User ID; website.
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 Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users who connect to the Site, URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and computer environment of the user. This data is used only to obtain statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuse.

Cookies and online trackers

This Cookie Policy refers exclusively to the website and must be understood as an integral part of its Privacy Policy.

1. Definitions, characteristics and application of the law

  Cookies are small text files that the websites visited by the User send and record on the User’s computer or mobile device, to be retransmitted to the same sites on the next visit. It is precisely thanks to cookies that a Website remembers the User’s actions and preferences (such as, for example, login details, the language chosen, font size, other display settings, etc.) so that they do not have to be entered again when the User returns to that Website or navigates from one page of it to another. Cookies, therefore, are used to perform computer authentication, session tracking and storage of information regarding the activities of Users accessing a Website and may also contain a unique identification code that allows the User’s navigation within the Website to be tracked for statistical or advertising purposes. During navigation on a Website, the User may also receive cookies from sites or web servers other than the one he is visiting on his computer or mobile device (so-called “third party cookies”). Some operations could not be carried out without the use of cookies, which in certain cases are therefore technically necessary for the Website to function itself.
There are various types of cookies, depending on their characteristics and functions, and they may remain on the User’s computer or mobile device for different periods of time: so-called “Session Cookies”, which are automatically deleted when the browser is closed; so-called “Persistent Cookies”, which remain on the User’s device until a fixed deadline.

2. Types of cookies used by the Website

Following in the text a list of the types of cookies:

  • “Statistics Cookies” — Also known as “Performance Cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited,
  • “Strictly necessary Cookies” — These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the Website. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. These cookies will generally be first-party session cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary should be explained to the User.
  • “Functionality Cookies” which allow the User to navigate according to a series of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided to the User.
  • “Analysis Cookies” from third party services. These cookies are used to collect anonymous information on the use of the Website by Users such as: pages visited, time spent, traffic origin, geographical origin, age, gender and interests for marketing campaigns. These cookies are sent by third party domains outside our sites.
  • “Cookies used to integrate third-party software products and functions”. This type of cookie integrates features developed by third parties within the pages of the Website such as icons and preferences expressed in social networks to share Website content or to use third party software services (such as map generation software and other software offering additional services). These cookies are sent by third party domains and partner sites that offer their functionality between Website pages.
  • “Marketing Cookies” are cookies necessary to create User profiles in order to send advertisements in line with User’s preferences within the pages of the Website.
  • “First-party Cookies” As the name implies, first-party cookies are put on your device directly by the website you are visiting.
  • “Third-party Cookies” — These are cookies from sites or web servers other than the Owner’s, used for purposes specific to such third parties, including analytical and profiling cookies.
  • “Session Cookies” These cookies are temporary and expire once you close your browser (or once your session ends).
  • “Persistent Cookies”— This category encompasses all cookies that remain on your hard drive until you erase them or your browser does, depending on the cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary. According to the ePrivacy Directive, they should not last longer than 12 months, but in practice, they could remain on your device much longer if you do not take action.

WARNING: disabling the “Strictly Necessary Cookies” and the “Functionality Cookies” may make the Website unavailable or certain services or functions of the Website may not function properly, and the User may be forced to modify or manually enter certain information or preferences each time he or she visits the Website.

The Website uses third party cookies, i.e. cookies from sites or web servers other than the Owner’s, used for purposes specific to such third parties, including analytical and profiling cookies. Please note that these third parties, listed below with the relevant hyperlinks to the privacy policies, act as autonomous data controllers of the data collected through cookies sent by them, therefore, the User must refer to their policies for the processing of Personal Data, information and any forms of consent collection (selection and de-selection of their respective cookies).
Below are the links to the respective information on the use of cookies by accessing and the consent forms provided:
This website uses Google Analytics, a web analysis service provided by Google, Inc. (“Google”).
Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how Users use the Website.
The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Questo Sito web utilizza i plugin e i cookie del sito gestito da Google YouTube. Il gestore delle pagine è YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. Quando l’Utente visita le pagine del sito dotate di un plugin/cookie per YouTube, non appena iniziate a riprodurre un video, viene stabilita una connessione ai server di YouTube. Questo indica al server YouTube quale delle nostre pagine avete visitato.
Se l’Utente ha effettuato l’accesso al tuo account YouTube, permette a YouTube di assegnare il suo comportamento di navigazione direttamente al suo profilo personale. È possibile evitare che ciò accada effettuando il logout dall’account YouTube. Per ulteriori informazioni su come vengono gestiti i dati degli utenti, consultare l’informativa sulla privacy di YouTube.

3. How to view and modify cookies through your browsing program (browser)

The User can select which cookies to delete (in whole or in part) through the specific functions of their browser: however, in the event that all or some of the cookies are disabled, it is possible that the Website may not be available for consultation or that some services or certain functions of the Website are not available or do not function correctly and/or the User may be forced to modify or manually enter certain information or preferences each time the Website is visited

How to disable cookies from third party services:
Third party cookies may be disabled by following the instructions provided at the following addresses:

4. Cookie settings

Below you can make a choice and specifically indicate which cookies to authorise.
The User is informed that not authorising technical cookies may result in the impossibility of using the Website, viewing its contents and using its services. Inhibiting “Strictly Necessary Cookies” and “Functionality Cookies” may mean that certain services or functions of the Website are not available or do not function correctly and the User may be forced to modify or manually enter certain information or preferences each time the Website is visited.
The lack of authorisation with respect to the other cookies indicated by third parties will not affect the functioning of the Website; however, since these types of cookies are sent exclusively by third parties, and since the Website owner cannot exercise control over the sending of these cookies to the User’s terminal, the relative opposition can only be exercised by accessing the consent forms prepared by the aforementioned third parties, if any, or through the settings of your browser. The links to the privacy policies and any forms for collecting consent to receive cookies set by third parties that send cookies through the Website are provided in the section Types of cookies used by the Website.
With regard to cookies directly sent by the Website owner, in addition to the procedure made available on this page, the Users may block or delete (in whole or in part) cookies also through the specific functions of their browser (see the above).
The choices made by the User with reference to the Website’s cookies will in turn be recorded in a special technical cookie, with the characteristics shown in the cookie table. This cookie may, however, in some circumstances not work correctly: in such cases, the User is advised to delete unwanted cookies and to inhibit their use also through the functionality of their browsing browser.
Your preferences with regard to cookies should be reset if you use different devices or browsers to access the Website.

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 Owner’s company o with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. This also includes subjects, entities or authorities, autonomous data controllers, to whom it is obligatory to communicate your Personal Data in accordance with the provisions of the law or by order of the authorities.

Legal basis of processing

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

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

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

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more please contact the Owner.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

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

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

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to 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 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: Analytics, Access to third-party accounts,  Contacting the User, statistics, advertising, subscription to newsletters, generic request for information, collection and analysis of CVs for purposes of collaboration or affiliation, respond to requests for assistance or information.
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”.

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 the Owner to obtain Public Personal Data from accounts on third party services and perform actions with them.
    Facebook account access (Facebook, Inc.)
    This service permits to view the User’s account on the social network Facebook, provided by Facebook, Inc., if a contact is made through the aforementioned platform. The data is used to respond to requests received and to provide the services deemed necessary as a result of such requests.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.
    Category of personal data collected according to CCPA: identifiers; california Consumer Records Statute information; biometric information; internet information; inferred information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Contacting the User
    By filling in the contact form with their Data, the User authorizes this Website 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: address; city; company name; country; county; date of birth; email address; fax number; first name; gender; last name; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code and other data provided by the user.
    Category of personal data collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Advertisement
  • Mailing list or newsletter:
    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase. Personal Data processed: address; city; company name; Cookies; country; county; date of birth; email address; first name; gender; last name; phone number; profession; state; Usage Data; website; ZIP/Postal code and other data provided by the user.
    Category of personal data collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Generic request of information (by phone call, e-mail or other contact methods)
    The User, by providing its Personal Data, authorizes the Owner to use these Data to reply to requests for information, quotes or any other kind of request. Personal Data processed: address; city; company name; country; county; date of birth; email address; fax number; first name; gender; last name; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code and other data provided by the user.
    Category of personal data collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Collection and analysis of curriculum vitae for collaboration or affiliation purposes
    The User, by sending a Curriculum Vitae containing his/her Personal Data, consents to their use for the collection and analysis with the aim of collaboration or affiliation.
    The Personal Data processed are chosen and provided by the User according to the typical purposes of the Curriculum Vitae and are provided freely and under the User’s responsibility.
  • Respond to requests for assistance or information:
    The User, by providing its Personal Data, authorizes the Owner to use these Data to reply to requests for information, quotes or any other kind of request. Personal Data processed: address; city; company name; country; county; date of birth; email address; fax number; first name; gender; last name; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code and other data provided by the user.
    Category of personal data collected according to CCPA: identifiers; commercial information; biometric information; internet information; employment related information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
  • Statistics:
    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 Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, (“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: United States – Privacy PolicyOpt Out; Ireland – Privacy PolicyOpt Out. Privacy Shield participant.
    Category of personal data collected according to CCPA: internet information.
    This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Specific information
At the User’s request, in addition to the information contained in this Privacy Policy, this Website could provide data subject with additional and contextual information regarding specific services of data process.

System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Limitations of liability

Klaxon Mobility GmbH shall not be liable in any way for any damage of any nature that is directly or indirectly caused by accessing the site, by the inability or impossibility of accessing it, by relying on the information contained therein or by using it.
Klaxon Mobility GmbH accepts no liability for any services offered by third parties with which the site has activated a link, and for any other content, information or anything else that contravenes the laws, that is contained in the third party resource linked to the attached link.
Any links to external sites are provided as a simple service to the Users, with the exclusion of any liability for the correctness and completeness of the totality of the links indicated.
Furthermore, the indication of links does not imply that Klaxon Mobility GmbH endorses or accepts any kind of liability for the completeness and correctness of the information contained in the sites indicated.

Definitions and legal references

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

Usage Data
Information collected automatically through this Website/Application (or third-party services)which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website/Application, the URI/URL addresses (Uniform Resource Identifier/Locator), 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 Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using this Website and/or that is submitting/communicating Personal Data (in any way possible) who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

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

This Website
One of the means by which the Personal Data of the User is collected and processed.

This Application
One of the means by which the Personal Data of the User is collected and processed.

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

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.

Cookies
Small sets of data stored in the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

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 who are consumers residing in the state of California, United States of America, according to “The California Consumer Privacy Act of 2018” (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we’ve collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, California Consumer Records Statute information, commercial information, biometric information, internet information, employment related information and inferred information. We will not collect additional categories of personal information without notifying you.

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

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use this Website.
For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.
We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.
To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale 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 another business or a third party, for monetary or other valuable consideration”.
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.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by this Website, both online and offline, you can contact us for further information using the contact details provided in this document.

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

We may use your personal information to allow the operational functioning of this Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

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

  • the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
  • in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • for sales, the personal information categories purchased by each category of recipient; and
    • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request. Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity 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 who reside in Brazil, according to the “Lei Geral de Proteção de Dados” (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

The grounds on which we process your personal information

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

  • your consent to the relevant processing activities;
  • compliance with a legal or regulatory obligation that lies with us;
  • the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymized personal information;
  • the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
  • the exercising of our rights in judicial, administrative or arbitration procedures;
  • protection or physical safety of yourself or a third party;
  • the protection of health – in procedures carried out by health entities or professionals;
  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
  • credit protection.

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

Categories of personal information processed

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

Why we process your personal information

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

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

Your Brazilian privacy rights

You have the right to:

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

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

How to file your request

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

How and when we will respond to your request

We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

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

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

Last update of this Privacy Policy: 15 October 2020.  

By using and browsing the Site you are acknowledging that you have read, understood and accepted all the above conditions.