Privacy Policy

Privacy Policy of www.kwameand.co
This Application collects some Personal Data from its Users.
Owner and Data Controller
Kwame & Co.
London
United Kingdom
Owner contact email: privacy@kwameand.co
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Trackers; Usage
Data; device information; browser information; email address; first name; last name; company name; 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
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.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this
Application 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.
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: Platform services and hosting, Analytics and Contacting the User.
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:
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 4
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the
Owner manages the Data processing, (“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.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or
server. Users can learn more by consulting Google’s official documentation.
Personal Data processed: browser information; device information; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – 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
targeted advertising according to the CPA, CTDPA and UCPA
Contacting the User
Mailing list or newsletter (this Application)
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 Application. Your email
address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: company name; email address; first name; last name; website.
Category of personal information collected according to the CCPA: identifiers; commercial information; internet or other
electronic network activity information.
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.
Webflow (Webflow, Inc.)
Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host this Application. Webflow is
highly customizable and can host websites from simple blogs to complex e-commerce platforms.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – 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 CPA, CTDPA and UCPA
targeted advertising according to the CPA, CTDPA and UCPA
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual
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
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.
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 California consumers
This section 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 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 (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in
the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as
updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section
supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act
(CCPA/CPRA).
Notice at collection
Categories of personal information collected, used, sold, or shared
In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes
thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of
Personal Data” within this document.
Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information and internet
or other electronic network activity information.
We do not collect sensitive personal information.
We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business
purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business
purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section
“Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and
defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed,
without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your
personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect?
We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this
Application.
For example, you directly provide your personal information when you submit requests via any forms on this Application. You
also provide personal information indirectly when you navigate this Application, as personal information about you is
automatically observed and collected.
Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the
functioning of this Application and features thereof.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose
For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as
defined by the CCPA.
We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the
processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the
different purposes of processing.
Sale or sharing of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring
or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a
third party, for monetary or other valuable consideration”, as defined by the CCPA.
This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or
views, or simply because it uses tools such as social network plugins and the like.
For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available,
transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information
by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable
consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit
of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the
requirements set by the CCPA, does not constitute a sale or sharing of your personal information.
Your right to opt out of the sale or sharing of your personal information and how you can exercise it
We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on
the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the
different purposes of processing.
You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop
selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control,
like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as
defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a
mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable
it via a participating browser or browser extension. More information about downloading GPC is available here.
We use any personal information collected from you in connection with the submission of your opt-out request solely for the
purposes of complying with the opt-out request.
Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Application and features thereof (“business
purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business
purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section
“Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and
defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed,
without your consent.
How long do we keep your personal information?
Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your
personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right
to request two separate lists from us where we disclose:
the categories of personal information that we sold or shared about you and the categories of third parties to whom the
personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to
whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to
enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as,
including but not limited to, where the information is used to identify and repair errors on this Application, to detect security
incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our
service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is
technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information
You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the
nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information
You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit
our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)
We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against
you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or
quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information,
and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete
that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping,
or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your
personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided
in this document.
For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by
making a verifiable request which must:
provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal
information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our
possession actually relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will use any personal information
collected from you in connection with the verification of your request solely for the purposes of verification and shall not further
disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State
to act on your behalf.
If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your
request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why,
and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after
January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide
them to you unless doing so proves impossible or would involve a disproportionate effort.
Should we deny your request, we will explain you the reasons behind our denial.
We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive.
In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices
and explain the reasons behind it.
Further information for Virginia consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is
provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in
the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such
consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the VCDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of
Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed,
without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing
of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the
consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.
Sale of your personal data
For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as
defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of
a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not
limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal
information may be considered a sale under VCDPA.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data,
we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details
provided in this document.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of
complying with the request.
Processing of your personal data for targeted advertising
We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will
grant your right to opt out of the processing of your personal data for targeted advertising.
Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data: the right to know. You have the right to request that we confirm whether or not we are processing
your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain
about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you
to transfer data easily to another entity — provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or
profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that
we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality
of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your
personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to
provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we
may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services
for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide
loyalty, rewards, premium features, discounts, or club card program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in
this document.
For us to respond to your request, we need to know who you are.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore
confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing
account. We will use any personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or
using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we
need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we
may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at
the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or
not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you
may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded,
excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our
choices and explain the reasons behind them.
Further information for Colorado consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is
provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in
the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other
possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of
Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed,
without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing
of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller,
processor, or affiliate of the processor or the controller." as defined by the CPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal
data may be considered a sale under the CPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable
consideration by a controller to a third party" as defined by the CPA.
Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a
controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited
to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data,
we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of
complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your
personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on
personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online
services to predict consumer preferences or interests" as defined by CPA.
Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response
to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or
online applications or any affiliated website or online application; advertisements based on the context of a consumer's current
search query, visit to an internet web site or online application; or processing personal data solely to measure or report
advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask
us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of
complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy
control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a
setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the
GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More
information about downloading GPC is available here.
Your privacy rights under the Colorado Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or
profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
access personal data. You have the right to request that we confirm whether or not we are processing your personal data.
You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain
about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that this is technically feasible.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of
any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may
offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee,
if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card
program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in
this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore
confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing
account. We will use any personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or
using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we
need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we
may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at
the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or
not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you
may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Further information for Connecticut consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is
provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in
the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The
Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or
conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the CTDPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of
Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed,
without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing
of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller,
processor, or affiliate of the processor or the controller." as defined by the CTDPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal
data may be considered a sale under the CTDPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable
consideration by a controller to a third party" as defined by the CTDPA.
Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of
a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not
limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data,
we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of
complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your
personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on
personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online
services to predict consumer preferences or interests" as defined by CTDPA.
Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a
controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit
to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for
information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask
us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of
complying with the opt-out request.
Universal opt-out mechanism: Global privacy control
If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy
control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a
setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the
GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More
information about downloading GPC is available here.
Your privacy rights under the Connecticut Data Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data. You have the right to request that we confirm whether or not we are processing your personal data.
You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain
about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or
profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of
any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may
offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee,
if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card
program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in
this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore
confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request.
Making a consumer request does not require you to create an account with us. However, we may require you to use your existing
account. We will use any personal data collected from you in connection with your request solely for the purposes of
authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or
using it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we
need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we
may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at
the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the
details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or
not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you
may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to one request per year.
Further information for Utah consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is
provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes
of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in
the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other
possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal data” as defined in the UCPA.
Categories of personal data processed
In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about
these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this
document.
Categories of personal data we collect
We have collected the following categories of personal data: identifiers, commercial information and internet information
We do not collect sensitive data.
We will not collect additional categories of personal data without notifying you.
Why we process your personal data
To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of
Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties
We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing
of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different
purposes of processing.
For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or
contractor of the controller or the processor" as defined by the UCPA.
Sale of your personal data
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal
data may be considered a sale under the UCPA.
For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable
consideration by a controller to a third party" as defined by the UCPA.
Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a
controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not
limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
Your right to opt out of the sale of your personal data and how you can exercise it
You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data,
we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of
complying with the request.
Processing of your personal data for targeted advertising
As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your
personal data for targeted advertising purposes.
For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on
personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online
services to predict consumer preferences or interests" as defined by UCPA.
Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a
controller's own websites or online applications or any affiliated website or online application; advertisements based on the
context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in
response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure
or report advertising performance, reach or frequency.”
Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it
You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask
us to stop processing your data for targeted advertising, we will abide by your request.
To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.
We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of
complying with the opt-out request.
Your privacy rights under the Utah Consumer Privacy Act and how to exercise them
You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:
access personal data. You have the right to request that we confirm whether or not we are processing your personal data.
You also have the right to access such personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to
transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.
In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of
any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may
offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee,
if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card
program.
How to exercise your rights
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in
this document.
For us to respond to your request, we need to know who you are and which right you wish to exercise.
We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore
confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional
information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to
your request.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we
need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we
may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at
the latest within 45 days of receipt of the request.
We do not charge a fee to respond to your request, for up to one request per year.
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.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -
that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.
Latest update: February 22, 2024

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