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PRIVACY POLICY

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Table of contents

Before you give us your consent on the processing of your personal data or provide us with your personal data within any form on our website, we kindly ask you to read this Privacy Policy carefully, so we can be sure that you completely understand the conditions under which we would cooperate.
This Privacy Policy explains when, where, and why we process personal data about people who use the Website, how we use it, the conditions under which we may disclose it to others, your rights in respect of your personal data, as well as how we keep it secure.

Interpretation of the terms

  • “Personal data” is any information relating to you and that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.
  • “Processing of the personal data” means any operation with your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • “Data subject” is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; it means you as a Customer of the Website.
  • “Consent of the data subject/user” is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which they, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to them.
  • “Website” refers to a website or a mobile application owned and operated by the Company:

Some other terms like Customer, Expert, Company, etc., are defined in our Terms and Conditions.

General

Whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt-out of cookies except those without which the Website cannot work.
When you are a registered Customer, we may collect from you and process Cookie identifiers and data you specifically provide us with upon registration.

Types of Data collected

The Company collects from you only the following information and only for the stated the below purposes:
Account for Customer
The Company collects and processes personal data submitted by you upon registration and further editing of settings in your account. For registration purposes, you are obliged to submit some necessary information. Please note that we are not responsible for any consequences caused by sharing your personal information with the Experts.
Order Details
The Company collects and processes your order details, including all the information you mention when you fill out the order form. The same applies to the information shared with the Expert via Messaging System and the instructions for the assignment.
Posting of Information
We process personal data freely submitted to you on the Website. This may be a survey you fill in on the Website or feedback you provide us with. The details of our communication include any information you provide us with when you contact our customer support team to ask questions and solve any possible problems.
The Company may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to the Website and to the Experts. You also acknowledge that parts of your content cannot be deleted as it may be connected to the Services received by you and used by the Experts.
Unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
Service Use, Cookies, and Other Similar Technologies
When you use our Services, we monitor and analyze web traffic and keep track of your behavior while using our Services. We may receive information about your IP address, proxy server, operating system, web browser, or mobile carrier and location based on phone settings. It helps us research the market and increase the quality of our service here at the Website. Additionally, we use cookies to understand and remember your preferences for your future visits.
All CAll Customers can choose to be notified by their browsers about each time a cookie file is sent. Also, they can turn off the cookies via browser settings. Please note that disabling cookies may affect or limit some features and functions on our Website. You will be able to place orders regardless of the cookies policies’ settings.
If you have already agreed to cookies on our website and want to change or disable them, please use the following instructions for your browser.
Billing Information
When you pay for a service on our Website, you provide us with payment and other information about you. Please note that we do not collect, process, or store your payment card details or other payment-related information on our Website. We just send it to third-party payment providers. Without this data, the Company would not be able to bill and provide you with the Service you have selected.
At the same time, for tax and financial reporting purposes, we store for a certain period of time only the following information: first 6 digits and last 4 digits of your card. We may need to identify you between various users for the transaction (e.g. when you reconcile your receipts) as well as the issuer of your card in some cases.
Sensitive Data
Unless you explicitly agree, the Company does not process your sensitive data.
Pages on Social Networks
We maintain the Company's official pages on social networks, such as Facebook. When you make interactions with our social network pages, such as subscribe to the pages, leave comments or preferences (e.g., ‘like’ our posts), we can analyze this data to measure our efficiency and conduct an analysis of our social media marketing in our legitimate interests.
Information Required for Submitting Tax Documentation
To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For submitting tax documentation, we may process your personal data, including but not limited to your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; Data communicated while using the service; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address.
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.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.

Mode and place of processing the Personal Data

Methods of processing. The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The Personal 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 Company, in some cases, the Data may be accessible to certain types of persons in charge, involved 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 Company. The updated list of these parties may be requested from the Company at any time.
Place. The Personal Data is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. Depending on the Customer’s location, data transfers may involve transferring the Customer’s Personal Data to a country other than their own. To find out more about the place of processing of such transferred data, Customers 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 Company 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: Heat mapping and session recording, Analytics, Advertising, Interaction with live chat platforms, Remarketing and behavioral targeting, Tag Management, Interaction with external social networks and platforms and Handling activity data.
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:
We may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of the Website to the fullest extent possible and to provide you with high-quality Services under the Terms and Conditions.
Provision of Services. We process your personal data to authorize access to our Services and to fulfill our obligations under the Terms and Conditions for Services provision. Specifically, we use your personal data upon registration to help the Experts find your account or profile in order to provide you the Services.Please note that without the information provided by you under our Terms and Conditions, we will be unable to provide you with the functionality of our Website and connect you with the Experts.
Payment Services. In order for you to use the Services, you will need to provide payment (e.g., credit card details) and billing information through our partners – third-party payment providers, which process your personal data by applying encryption and other security measures. Please see our Refund Policy for more information.
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Correspondingly all transactions are secured as our partners-payment providers use encryption protection. We do not store your payment information on our servers.
We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred and that you qualify for a promotional offer; for example, the date and amount of your purchase and the last four digits of your card number so that we can verify your purchase with our records.
Communications. We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, Website updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with the Experts.
Your contact data (including email, phone number, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:
  • Feature development and product updates;
  • Marketing activities;
  • Support updates;
  • Other service updates for improving your experience.
Having received the communications from us, you are always able to opt-out of such communications in each message, excluding legal notices or changes to user settings on the Website.
Marketing and Promotion. We may process your personal data in order to analyze, personalize and improve our marketing practices unless our actions in this regard require your specific consent. We can also send you direct marketing emails and special offers unless our actions in this regard require your specific consent.
But you may always opt-out of our marketing messages, using the mechanisms described under the respective link in each message and through the user settings.
Analytics and Development. In order to establish new ways to improve the Website, find the points of interest in our Services and for the purposes of analytics, we monitor and analyze the personal data you provide us with, including information you provide upon the registration, the web traffic, cookies and usage data, such as the date and duration of your visit, your location, type of the device you used during your visit and other relevant data on the use of the Website.
The purpose of such analytics is to understand Customer engagement and satisfaction with certain features in order to improve the Customer experience, develop new useful features, and streamline our Services.
We may also carry out polls and surveys through the Website using external compliant services. You are not obliged to respond to them, and you may opt-out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Customer data and cookies.
Support. In case of any disputes on the Website, we may use data (including communications) to resolve such matters, supervise Customer and Expert behavior on the Website, and respond to any complaints or requests.
Compliance with Legal Requirements. We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.
Fraud Prevention. Certain information, such as your log information, payment information, and your behavior on the Website are subject to our supervision to prevent fraudulent activities on the Website and assist you with your needs.
Changes. If the Website decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification of such changes will be sent to your email, and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.In case you do not want to provide us with the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.
Archival Purposes. We may archive your information in the event of a legal need to prove certain events (e.g., in the establishment, pursuit, or defense of claims), which is our legitimate interest.
Responding to Contact Initiated by You. When you contact us (e.g., via contact forms, email, or chatbots), you may provide us with your contact info, which we may use to respond to you. Providing information about the Company is our legitimate interest.
Combating Inappropriate Behavior and Promoting Safety. We examine information about the operation and use of our Website to verify Customers and accounts, enhance security and combat inappropriate behavior, spam, or fraud. In doing so, we ensure our Website is used in accordance with our Terms and Conditions and remains free of harmful and inappropriate content. Securing our Website and keeping it a safe place for our users is our legitimate interest.
Aggregate/De-Identify/Anonymize Data. We may aggregate, de-identify, and/or anonymize any information collected through our Website and our services so that such information is no longer linked to your personally identifiable information (such as your name or email address). We may use aggregated and anonymized information for any purpose, including for research and marketing purposes, and we may also share such information with third parties at our discretion.

Your Rights As Data Subject

Right of Confirmation. You can obtain confirmation from the Company as to whether personal data concerning you is being processed.
Right of Access. You can access your personal data processed by the Company.
Right to Rectification. You can ask the Company to have incomplete personal data requiring corrections completed.
Right to Erasure (Right to Be Forgotten). You can request the Company to erase personal data. In most cases, the Company will erase it unless otherwise required by legislation. To delete your personal data, you can:
  • Contact us by email at support@savemygrade.com. We will respond to your request to delete your information within five days and notify you of the outcome. In the request, you must state your full legal name, address, phone number, and email that you used to sign up to the website to identify your account. You must also provide a reason why you want your data deleted and list the information that you are specifically aware of as being processed and retained by the Company. If you wish for all the data to be deleted from the system, please state so in the official letter as well.
  • Delete specific items from your account (such as your payment method, etc.).
  • Delete your entire account.
  • Right of Restriction of Processing
You can contest the accuracy of your personal data, or in case the Company is not interested in processing your personal data any longer, but you want the Company to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.
‍Right to Data Portability. You can have your personal data transmitted directly from one controller to another, where technically feasible, and when doing so does not adversely affect the rights and freedoms of others.
Right to Object to Processing of Your Personal Data by the Company.
You can object to our processing of your personal data when the processing is related to the performance of our task carried in the public interest or the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party, and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with an objection to processing, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing.
Right to Withdraw Consent at any Time by Contacting Us. After we receive a withdrawal request from you, we will process it in a timely manner, and we will no longer process your personal data unless otherwise set by law.
If one of the aforementioned reasons applies, please contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately. These requests are free of charge.
If you believe that our use of your data violates your rights, you can lodge a complaint with the competent data protection authority. Please note that when the processing of your personal data is carried out for direct marketing purposes, you have the right to object at any time to such processing without providing any justification and we will no longer process your data for such direct marketing purposes.
Right to Request a Copy of Your Personal Data. As a registered user, you can also check the data you have provided in your Account.
Right to Request the Company to Correct Any Information About You. If you believe that it is incorrect, outdated, or incomplete, do not hesitate to contact us if you make a mistake during registration or when completing your user profile.
We may ask you questions regarding your user account in an effort to verify your identity. We will make every effort to allow you to exercise your rights as soon as possible and no later than as required by applicable law. If we need to extend the processing period for your application in accordance with applicable law, we will inform you of the extension period and explain the reasons for the delay.
Ensuring a high level of personal data protection is a priority for the Company.

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 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”).
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:
We do not collect sensitive personal information. We will not collect additional categories of personal information without notifying you.
What are the purposes for which we use your personal information? We may use your personal information to allow the operational functioning of this Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.
We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
How long do we keep your personal information? Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.
How we collect information: what are the sources of the personal information we collect? We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Website.
For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, as personal information about you is automatically observed and collected.
How we use the information we collect: disclosing of your personal information with third parties for a business purpose. We do not disclose your personal information to third parties. 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.
No sale of your personal information. We do not sell or share your personal information. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.
Your privacy rights under the California Consumer Privacy Act and how to exercise them
The right to access personal information: the right to know and to portability
You have the right to request that we disclose to you:
  • the categories of personal information that we collect about you;
  • the sources from which the personal information is collected;
  • the purposes for which we use your information;
  • to whom we disclose such information;
  • the specific pieces of personal information we have collected about you.
You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:
  • the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
  • the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
The disclosure described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.
The right to request the deletion of your personal information. You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).
If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.
The right to correct inaccurate personal information. You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information. You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.
The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination). We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.
However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.
How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document. For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you. Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf. If you are an adult, you can make a verifiable request on behalf of a 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 it 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 Personal Data” within this document.
Categories of personal data we collect. 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 do not share nor disclose your personal data with third parties.
Sale of your personal data. We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.
Processing of your personal data for targeted advertising. We process 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 a 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 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”).
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 Personal Data” within this document.
Categories of personal data we collect. We have collected the following categories of personal data: We do not collect sensitive data. We will not collect additional categories of personal data without notifying you.
Why we process your personal data. To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties. We do not share nor disclose your personal data with third parties. 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.
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. We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.
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.
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.
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 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 a 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 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”).
This section applies to 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 Personal Data” within this document.
Categories of personal data we collect. We have collected the following categories of personal data: We do not collect sensitive data. We will not collect additional categories of personal data without notifying you.
Why we process your personal data. To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.
How we use the data we collect: sharing of your personal data with third parties
We do not share nor disclose your personal data with third parties.
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. We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.
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.
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.
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 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 a 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 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”).
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 Personal Data” within this document.
Categories of personal data we collect. We have collected the following categories of personal data: We do not collect sensitive data. We will not collect additional categories of personal data without notifying you.
Why we process your personal data. To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
How we use the data we collect: sharing of your personal data with third parties. We do not share nor disclose your personal data with third parties. 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. We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale. 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.
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.
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 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 Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data. In addition to the information contained in this privacy policy, this Website may provide the User with additional and 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 Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please 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 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.

Contact Us

If you have questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us in one of the following ways:
Updated: Apr 1st, 2024