Privacy Policy

Privacy Policy

This application collects some personal information from its users.

This document includes a section dedicated to California consumers and their privacy rights

This document includes a section dedicated to Virginia consumers and their privacy rights

This document can be printed for reference using the print command in each browser's settings.

Policy Summary

Personal data processed for the following purposes and using the following services:

Collection of privacy-related preferences

Personal information: data that is communicated while using the service; Trackers

Contacting the user

  • Contact form
  • Personal information: date of birth; email address; usage data; username
  • Mailing list or newsletter
  • Personal information: email address; first name; phone number; usage data

Device permissions to access personal information

  • Device permissions to access personal information
  • Personal information: estimated location permission (not continuous); consent to access biometric data; Bluetooth sharing consent; consent to read health data; consent to update health data;

Activity data processing

  • Activity data that is maintained by your device
  • Personal information: date of birth; gender; general activity data; heart rate and other essential information; movement activity

Data Collection Management and Online Surveys

  • Data provided via online forms, managed directly
  • Personal information: answers to questions; date of birth; email address; gender

Registration and Authentication

  • Google OAuth
  • Personal information: various types of data as specified in the service's privacy policy

Registration and authentication are provided directly by this application

  • Direct registration
  • Personal information: city; country; date of birth; email address; first name; gender; last name; password; phone number; user name; username; username

Analytics

  • Google Analytics 4
  • Personal information: browser information; city; device information; number of users; session statistics; usage data
  • Google Analytics for Firebase
  • Personal information: Application opening; Application updates; device information; geography/region; launches; number of sessions; number of users; operating systems; session duration; usage data

Hosting and backend infrastructure

  • Amazon Web Services (AWS)
  • Personal information: various types of data as specified in the service's privacy policy

Infrastructure supervision

  • Sentry
  • Personal information: various types of data as specified in the service's privacy policy

View content from external platforms

  • Google fonts
  • Personal information: trackers; usage data

Tag Management

  • Google Tag Manager
  • Personal information: trackers; usage data

Platform services and hosting

  • Webflow
  • Personal information: trackers; usage data; various types of data as specified in the service's privacy policy

More information about the processing of personal data

Equal protection of user data

This application only shares user information with third parties that have been carefully selected to ensure that they provide the same or equal protection of user data as stated in this Privacy Policy and required by applicable data protection laws. More information about data processing and privacy practices by third parties can be found in their respective privacy policies.

Full policy

Owner and Data Controller

Types of data that are collected

Among the types of personal information that this application collects by itself or through third parties, there are: estimated location permission (non-continuous); Bluetooth sharing consent; consent to access biometric data; precise location permission (not continuous); consent to read health data; consent to update health data; trackers; data transferred while using the service; date of birth; email address; user ID; usage data; first name;; phone number; username; password; country; city; gender; general activity data; movement activity; heart rate and other essential data; answers to questions; number of users; device information; session statistics; browser information; geography/region; number of sessions; session duration; Application opens; Application updates; launches; operating systems; various types of data.

Full information about each type of personal information collected can be found in the special sections of this Privacy Policy or in specific explanations that appear before data collection.
Personal data can be provided free of charge by the user or, in the case of usage data, collected automatically when using this application.
Unless otherwise stated, all information requested by this application is mandatory and if this information is not provided, this application may not be able to provide its services. In cases where this Application specifically states that certain Data is not mandatory, Users are free not to share this Data without consequences for the availability or operation of the Service.
Users who are not sure what personal information is mandatory can contact the owner.
Any use of cookies — or other tracking tools — by this Application or by the owners of third-party services used by this Application serves to provide the Service that the User needs, in addition to any other purposes described in this document and in the Cookie Policy, if available.

Users are responsible for all third party personal information obtained, published or shared through this application and confirm that they have permission from the third party to provide the information to the owner.

Method and place of processing the data

Processing methods

The owner takes appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of the data.
Data processing is carried out using computers and/or IT tools, in accordance with organizational procedures and modes strictly related to the specified purposes. In addition to the Owner, the Data may in some cases be accessible to certain types of controllers involved in the operation of this Application (administration, sales, marketing, legal matters, systems administration) or third parties (such as external technical service providers, postal carriers, hosting providers, IT companies, communication agencies) who, if necessary, have been appointed as data processors by the Owner. The updated list of these parties can be requested from the Owner at any time.

Legal basis for processing

The owner can process personal data related to users if one of the following situations applies:

  • Users have given their consent for one or more specific purposes. Note: Under some laws, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”) without relying on consent or any of the following legal bases. However, this does not apply when the processing of personal data is subject to European data protection laws;
  • providing data is necessary for the execution of an agreement with the user and/or for any pre-contractual obligations thereof;
  • the processing is necessary to comply with a legal obligation to which the Owner is subject;
  • the processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner;
  • the processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner is happy to help clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a legal or contractual requirement, or a requirement necessary to enter into a contract.

Locality

The data is processed in the owner's operational offices and in all other places where the parties involved in processing are located.

Depending on the user's location, data transfer may include transferring user data to a country other than their home country. To find out more about the place of processing of such transferred data, users can refer to the section containing information about the processing of personal data.

Users also have the right to know about the legal basis for data transfers to a country outside the European Union or to an international organization that is governed by public international law or established by two or more countries, such as the UN, and about the security measures that the Owner has taken to protect their data.

If such a transfer occurs, Users can find more information by reviewing the relevant sections of this document or contacting the Owner using the information in the contact section.

Storage time

Personal data is processed and stored for as long as necessary for the purpose for which it was collected.

That's why:

  • Personal data collected for purposes related to the performance of a contract between the owner and user will be kept until such contract has been fully executed.
  • Personal data collected for the owner's legitimate interests will be kept for as long as necessary to fulfill such purposes. Users can find specific information about the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner.

The owner may be allowed to keep personal information for a longer period of time when the user has consented to such processing, as long as such consent is not withdrawn. In addition, the owner may be required to keep personal information for a longer period of time when this is necessary for the performance of a legal obligation or by order of an authority.

Once the retention period has expired, the personal data will be deleted. Therefore, the right to access, the right to delete, the right to rectification and the right to data portability cannot be enforced after the expiration of the storage period.

The purposes of the processing

User data is collected to enable the owner to provide its services, 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: device permissions to access personal information, collection of privacy-related preferences and contacting the user.

For specific information about the personal data used for each purpose, the user can refer to the “Detailed information on the processing of personal data” section.

Device permissions to access personal information

Depending on the user's specific device, this application may request certain permissions to access the user's device information, as described below.

By default, these permissions must be granted by the user before access to the relevant information can be accessed. Once the consent has been given, it can be withdrawn by the user at any time. To revoke these permissions, Users can review device settings or contact the Owner for assistance using the contact information in this document.
The exact procedure for managing app permissions may vary depending on the user's device and software.

Please note that revoking such permissions may affect the proper functioning of this application.

If the user grants one of the permissions listed below, the respective personal data may be processed (i.e. accessed, modified or deleted) by this application.

Estimated location permission (not ongoing)

Used to access the estimated location of the user's device. This application may collect, use, and share user location information to provide location-based services.
The user's geographic location is determined in a way that is not continuous. This means that it is impossible for this application to continuously deduce the user's estimated position.

Permission to access biometric data

Used to access the user's biometric data and/or authentication systems, such as FaceID.

Bluetooth sharing permission

Used to access Bluetooth-related features, such as scanning to devices, connecting to devices, and enabling data transfer between devices.

Health data reading permission

Enables the user's health data to be read.

Permission to update health data

Allows the user's health information to be updated.

Detailed information about the processing of personal data

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

Contacting the user

Contact form (this application)

By completing the contact form with their details, the user authorizes this application to use this data to respond to requests for information, quotes or any other type of request, as indicated in the header of the form.

Personal data processed: date of birth; email address; Usage data; User ID.

Category of personal information collected under the CCPA: identifiers; Internet information.

This processing includes: a sale under the CCPA and the VCDPA

Mailing list or newsletter (this application)

By registering on the mailing list or for the newsletter, the user's email address is added to the contact list of those who may receive emails containing commercial or promotional information about this Application. Your email address can also be added to this list if you have signed up for this application or after making a purchase.

Personal data processed: email address; first name; telephone number; usage data.

Category of personal information collected under the CCPA: identifiers; Internet information.

This processing includes: a sale under the CCPA and the VCDPA

Device permissions to access personal information

This application requests users certain permissions to access the user's device information, as described below.

Device permissions to access personal information (this application)

This application requests users certain permissions to access the user's device information, as summarized here and described in this document.

Personal data processed: estimated location permission (non-continuous); consent to access biometric data; Bluetooth sharing consent; consent to read health data; consent to update health data; precise location permission (not continuous).

Category of personal information collected under the CCPA: biometric information; internet information; geolocation data.

Activity data processing

This type of service allows the Owner to use the activity data collected by your device to make this application work or provide specific features. This can include movements, heart rate, altitude changes or data about the environment.
Depending on what's described below, third parties may be involved in tracking activities.
On most devices, the user can control what data is opened or stored.

Activity data maintained by your device (this application)

This application uses certain activity data that is maintained by your device to work or provide specific features.

Personal data processed: date of birth; gender; general activity data; heart rate and other essential data; movement activity.

Category of personal information collected under the CCPA: identifiers; biometric information; geolocation information.

This processing consists of: a division according to the CCPA

Registration and Authentication

By registering or authenticating, users allow this application to identify them and give them access to special services.
Depending on what is described below, third parties may offer registration and authentication services. In that case, this application has access to certain data stored by these external services for registration or identification purposes.
Some of the services below may also collect personal data for targeting and profiling purposes; for more information, please refer to the description of each service.

Google OAuth

Google OAuth is a registration and authentication service provided by Google LLC or Google Ireland Limited, depending on how the owner manages data processing, and is connected to the Google network.

Personal data processed: various types of data as specified in the service's privacy policy.

Place of processing:

United States — Privacy PolicyIreland — Privacy Policy

Category of personal information collected under CCPA: identifiers.

This processing includes: a sale under the CCPA and the VCDPA

Data Collection Management and Online Surveys

This type of service allows this application to manage the creation, implementation, administration, distribution, and analysis of online forms and surveys to collect, store, and reuse data from all responding users.
The personal data collected depends on the information requested and provided by the users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take further steps with the Data processed, such as managing contacts, sending messages, analytics, advertising and payment processing.

Data provided via online forms and managed directly (this application)

This application uses online forms that can be used to collect information about users.

Personal data processed: answers to questions; date of birth; email address; gender.

Category of personal information collected under CCPA: identifiers; derivative information.

This processing consists of: a division according to the CCPA

Registration and authentication are provided directly by this application

By registering or authenticating, Users allow this Application to identify them and give them access to special services. The personal data is collected and stored for registration or identification purposes only. The data collected is only necessary for the provision of the service requested by users.

Direct registration (this application)

The user registers by completing the registration form and providing the personal data directly to this application.

Personal data processed: city; country; date of birth; email address; first name; gender; last name; password; phone number; usage data; username.

Category of personal information collected under the CCPA: identifiers; Internet information.

This processing consists of: a sale according to the VCDPA; targeted advertising according to the VCDPA

Analytics

The services in this section allow the Owner to monitor and analyze web traffic and can be used to track user behavior.

Google Analytics 4

Google Analytics 4 is a web analysis service provided by Google LLC or Google Ireland Limited, depending on how the owner manages data processing (“Google”). Google uses the collected data to track and investigate the use of this application, to compile activity reports and share them with other Google services.
Google can use the collected data to contextualize and personalize the ads from its own advertising network.
In Google Analytics 4, IP addresses are used during collection and then deleted before data is registered in a data center or server. Users can learn more by consulting Official Google documentation.

Personal data processed: browser information; city; device information; number of users; session statistics; usage data.

Place of processing: United States — Privacy Policyunsubscribe; Ireland — Privacy Policyunsubscribe.

Category of personal information collected under the CCPA: identifiers; Internet information.

This processing consists of: a division according to the CCPA

Google Analytics for Firebase

Google Analytics for Firebase or Firebase Analytics is an analysis service provided by Google LLC or Google Ireland Limited, depending on how the owner manages data processing.
To understand Google's use of data, see Google's Partner Policy.

Firebase Analytics can share data with other Firebase tools, such as crash reporting, authentication, remote configuration, or notifications. The user can review this privacy policy to find a detailed explanation of the other tools used by the Owner.

This application uses mobile device identifiers and technologies similar to cookies to perform the Firebase Analytics service.

Users can opt out of certain Firebase features via the applicable device settings, such as mobile phone ad settings on the device, or by following the instructions in other Firebase-related sections of this Privacy Policy, if available.

Personal data processed: Application opening; Application updates; device information; geography/region; launches; number of sessions; number of users; operating systems; session duration; usage data.

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

Category of personal information collected under the CCPA: Internet information; geolocation data.

This processing consists of: a division according to the CCPA

Hosting and backend infrastructure

The purpose of this type of service is to host data and files that allow Glimp to run and distribute, and to provide a ready-to-use infrastructure to perform specific functions or components of Glimp.

Some of the services listed below, if applicable, may operate via geographically distributed servers, making it difficult to determine the actual location where personal information is stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal data processed: various types of data as specified in the service's privacy policy.

Place of processing: Frankfurt, Germany — Privacy Policy.

Infrastructure supervision

With this type of service, Glimp can monitor the use and behavior of the components so that performance, operation, maintenance, and troubleshooting can be improved.
The personal data that is processed depends on the characteristics and method of implementing these services, which aim to filter Glimp's activities.

Sentry (Functional Software, Inc.)

Sentry is a security service provided by Functional Software, Inc.

Personal data processed: various types of data as specified in the service's privacy policy.

Place of processing: United States — Privacy Policy.

View content from external platforms

This type of service allows you to view and interact with content hosted on external platforms directly from the pages of this application.
This type of service can still collect web traffic data for the pages where the service is installed, even if users are not using it.

Google fonts

Google Fonts is a font visualization service provided by Google LLC or Google Ireland Limited, depending on how the owner manages data processing, which allows this application to include such content on its pages.

Personal data processed: Trackers; Usage Data.

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

Category of personal information collected under the CCPA: Internet Information.

This processing consists of:

  • a sale under the CCPA and the VCDPA

Platform services and hosting

These services aim to host and run the key components of this application, allowing the delivery of this application from a unified platform. Such platforms provide the Owner with a wide range of tools — for example, analytics, user registration, commenting, database management, e-commerce, payment processing — that involve the collection and processing of personal data.
Some of these services operate via geographically distributed servers, making it difficult to determine the actual location where personal data is 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: trackers; usage data; various types of data as specified in the service's privacy policy.

Place of processing: United States — Privacy Policyunsubscribe.

Category of personal information collected under the CCPA: identifiers; Internet information.

Tag Management

This type of service helps the owner to manage the tags or scripts required for this application in a centralized way.
This means that users' data flows through these services, which may result in the storage of this data.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or Google Ireland Limited, depending on how the owner manages data processing.

Personal data processed: Trackers; Usage Data.

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

Category of personal information collected under the CCPA: Internet Information.

More information about the processing of personal data

Equal protection of user data

This application only shares user information with third parties that have been carefully selected to ensure that they provide the same or equal protection of user data as stated in this Privacy Policy and required by applicable data protection laws. More information about data processing and privacy practices by third parties can be found in their respective privacy policies.

Users' rights

Users can exercise certain rights with respect to their data processed by the Owner.

In particular, users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw their consent if they have previously given their consent to the processing of their personal information.
  • Object to the 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. More information can be found in the special section below.
  • Access to their data. Users have the right to know whether data is being processed by the owner, to obtain information about certain aspects of the processing, and to obtain a copy of the data being processed.
  • Verify and ensure rectification. Users have the right to verify the accuracy of their data and request that it be updated or corrected.
  • Restrict the processing of their data. Under certain circumstances, users have the right to restrict the processing of their data. In this case, the Owner does not process his data for purposes other than storage.
  • Have their personal information deleted or otherwise deleted. Under certain circumstances, users have the right to obtain the deletion 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 possible, to have it transmitted unhindered to another controller. This provision applies provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract that includes the user, or on pre-contractual obligations thereof.
  • File a complaint. Users have the right to file a claim with their competent data protection authority.

Details of the right to object to processing

When personal data is processed for a public interest, in the exercise of 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 reason related to their particular situation to justify the objection.

However, users should know that if their personal data is processed for direct marketing purposes, they can object to that processing at any time without any justification. If the user objects to processing for direct marketing purposes, the personal data will no longer be processed for such purposes. To find out whether the Owner processes personal data for direct marketing purposes, Users can consult the relevant sections of this document.

How to exercise these rights

All requests to exercise user rights can be addressed to the Owner using the contact details in this document. These requests can be submitted free of charge and will be answered by the Owner as soon as possible and always within one month, providing Users with the information required by law. Any rectification or deletion of personal data or restriction of processing will be notified by the owner to each recipient, if applicable, to whom the personal data has been provided, unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform them about these recipients.

Additional information about data collection and processing

Legal action

The user's personal data may be used by the owner for legal purposes in court or in the stages leading to possible legal action due to improper use of this application or the related services.
The user declares that he is aware that the Owner may be required to disclose personal information at the request of government agencies.

Additional information about the user's personal information

In addition to the information in this privacy policy, this application may provide the user with additional and contextual information about certain 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 information (such as IP address) for this purpose.

Information not included in this policy

More information about the collection or processing of personal data can be requested from the owner at any time. See contact information at the beginning of this document.

How “" Do Not Track "” requests are handled”

This application does not support “Do Not Track” requests.
Read their privacy policies to determine whether any of the third-party services it uses complies with the “Do Not Track” requests.

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 technically and legally feasible - by sending a notice to Users using any contact information available to the Owner. It is strongly recommended that you visit this page regularly, referring to the date of the last change listed at the bottom.

If the changes affect processing activities carried out on the basis of the user's consent, the Owner will seek new consent from the User if necessary.

Information for California Consumers

This part of the document integrates with and supplements the information in the rest of the Privacy Policy and is provided by the company that operates this application and, if applicable, the parent company, subsidiaries, and affiliates (collectively referred to as “we”, “us”, “our” for the purposes of this section).

The provisions in this section apply to all users (Users are simply referred to below as “you”, “your”, “your”), who are consumers residing in the state of California, United States of America, according to the”California Consumer Protection Act of 2018“(the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, these provisions replace any other terms that may differ or conflict in the privacy policy.

This section of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).

Notification at the time of collection

Categories of personal information that is collected, used, sold, or shared

In this section, we summarize the categories of personal information that we collected, used, sold, or shared and their purposes. You can read more about these activities in the section entitled “Detailed information about the processing of personal data” in this document.

Information we collect: The categories of personal information that we collect

We collected the following categories of personal information about you: identifiers, biometric information, Internet information, geolocation data, and derivative information.

We collected the following categories of sensitive personal information: consent to access biometric data, precise location permission (not continuous), consent to read health data, consent to update health data, exercise activity, heart rate and other essential data, user name and password.

We will not collect additional categories of personal information without notifying you.

Your right to restrict the use or disclosure of your sensitive personal information and how to exercise it

You have the right to request that we limit the use or disclosure of your sensitive personal information to only what is necessary to perform the services or deliver the goods, as reasonably expected by an average consumer.

We may also use your sensitive personal information for specific purposes set out in law (such as, but not limited to, helping to ensure safety and integrity; engaging in activities to verify or maintain the quality or safety of our service) and as permitted by relevant regulations.

In addition to the specific purposes set out above, you have the right to freely request that we do not use or disclose your sensitive personal information at any time. This means that when you ask us to stop using your sensitive personal information, we will comply with your request and instruct our service providers and contractors to do the same.

To fully exercise your right to restrict the use or disclosure of your sensitive personal information, you may contact us at any time using the contact details in this document.

For a simplified opt-out method, you can also use the link to privacy choices offered on this application.

We only use any personal information collected from you in connection with the submission of your request to fulfill the request.

Once you exercise this right, we must wait at least 12 months before asking if you have changed your mind.

For what purposes do we use your personal information?

We may use your personal information to enable the operational operation of this application and its functions (“business purposes”). In such cases, your personal information will be processed in a manner that is 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 specified in the “Detailed Information about the Processing of Personal Data” section of this document), as well as to comply with the law and defend our rights with competent authorities when our rights and interests are threatened or we are actually harmed.

We do not process your information for unexpected purposes or for purposes that are incompatible with those originally disclosed without your consent.

How long do we keep your personal information?

Unless otherwise stated in the “Detailed Information about the Processing of Personal Data” section, we will not keep your personal information longer than reasonably necessary for the purposes for which it was collected.

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

We collect the above categories of personal information, directly or indirectly, from you when you use this application.

For example, you provide your personal information directly when you submit requests using a form on this Application. You also provide personal information indirectly when you navigate through this application because personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties who work with us in connection with the Service or the operation of this Application and its features.

How we use the information we collect: Disclosure of your personal information to third parties for business purposes

For our purposes, the word “third party” means a person who is not one of the following: a service provider or contractor, as defined by the CCPA.

We disclose your personal information to third parties detailed in the section entitled “Detailed information about the processing of personal data” in this document. These third parties are grouped and categorized according to the different processing purposes.

Selling or sharing your personal information

For our purposes, the word “sell” means any “sale, rental, release, disclosure, dissemination, making available, transferring, or otherwise communicating a consumer's personal information orally, in writing, or electronically to” a third party, for monetary or other valuable compensation”, as defined by the CCPA.

This means that a sale can take place, for example, when an application displays ads or makes statistical analyses of traffic or views, or simply because tools such as social network plug-ins, etc., are used.

For our purposes, the word “share” any “” means sharing, renting, releasing, disclosing, distributing, making available, transferring, or otherwise communicating a consumer's personal information orally, in writing, or in any other way by the company to a third party for contextual behavioral advertising, whether for monetary or other valuable consideration, including transactions between a company and a third party for contextual behavioral advertising for the benefit of a business in which there is no money exchanged”, as defined by the CCPA.
Please note that exchanging personal information with a service provider under a written contract that meets the requirements of the CCPA does not involve selling or sharing your personal information.

Your right to opt out of selling or sharing your personal information and how to exercise it

We sell or share your personal information with third parties detailed in the section entitled “Detailed information about the processing of personal data” in this document. These third parties are grouped and categorized according to the different processing purposes.

You have the right to opt out of selling or sharing your personal information. This means that when you ask us to stop selling or sharing your personal information, we will comply with your request.
Such requests can be made freely at any time without making a verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details in this document.
For a simplified opt-out method, you can also use the link to privacy choices offered on this application.

If you want to make requests to opt out of selling or sharing personal information through a global privacy management enabled by the user, such as Global Privacy Control (”GPC”), you are free to do so and we will comply with any 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 that they support the GPC signal. 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 only use any personal information collected from you in connection with the submission of your opt-out request to comply with the opt-out request.

After you log out, we'll have to wait at least 12 months before asking if you've changed your mind.

Your privacy rights under the California Consumer Privacy Act and how to exercise them

Right to access personal information: right to information and portability

You have the right to request that we provide you with information about:

  • the categories of personal information that we collect about you;
  • the sources from which personal information is collected;
  • the purposes for which we use your information;
  • to whom we provide such information;
  • the specific personal information that we have collected about you.

You also have the right to know what personal information is being sold or shared and to whom. In particular, you have the right to request two separate lists from us where we provide information:

  • 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 have provided about you for business purposes and the categories of people to whom it was provided for business purposes.

The disclosure described above is limited to personal information collected or used in the past 12 months.

If we provide our response electronically, the attached information is “transferable”, i.e. provided in an easy-to-use format so that you can transmit the information unhindered to another entity — provided that this is technically possible.

The right to request the deletion of your personal information

You have the right to ask us to delete all of your personal information, subject to exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors in this application, to detect security incidents and protect against fraudulent or illegal activity, 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 all our service providers and any third party to whom we sold or shared the personal information to do so — provided that this is technically feasible and does not require disproportionate efforts.

Right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of processing the personal information.

The right to opt out of selling or sharing personal information and to restrict the use of your sensitive personal information

You have the right to opt out of selling or sharing your personal information. You also have the right to request that we restrict our use or disclosure of your sensitive personal information.

Right not to retaliate after opting out or exercising other rights (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, refusing goods or services, charging you a different price, or offering goods or services of a different level or quality simply because you have 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 if that personal information or sale is necessary to provide you with goods or services, we may not be able to complete that transaction.

To the fullest extent permitted by law, we may offer you promotions, discounts, and other offers in exchange for collecting, storing, 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 must submit your verifiable request to us by contacting us using the information in this document.

In order to respond to your request, it is necessary that we know who you are. Therefore, you can only exercise the above rights by submitting a verifiable request that:

  • provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative;
  • Please describe your request with sufficient detail so that we can 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 that the personal information in our possession actually relates to you.

If you make a verifiable consumer request, you don't need to create an account with us. We will only use any personal information that we have collected from you in connection with the verification of your request for verification purposes and will not further disclose the personal information, keep it longer than necessary for verification purposes, or use it for unrelated purposes.

If you are unable to make a verifiable request in person, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum of 2 applications over a period of 12 months.

How and when we are expected to handle your request

We'll 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 receipt. If we need more time, we'll explain why and how much more time we need. In this regard, please note that it may take up to 90 days for us to comply with your request.

Our disclosure (s) will relate to the previous 12-month period. Only with respect to personal information collected on or after January 1, 2022, do you have the right to request that we disclose information after the 12 month period, and we will provide it to you unless this proves impossible or would require a disproportionate effort.

If we reject your request, we will explain the reasons for our rejection.

We do not charge a fee to process or respond to your verifiable request unless such request is clearly unfounded or excessive. In such cases, we may charge or decline a reasonable fee to comply with the request. In either case, we will communicate our choices and explain the reasons behind them.

Information for Virginia Consumers

This part of the document integrates with and supplements the information in the rest of the Privacy Policy and is provided by the controller operating this application and, if applicable, the parent company, subsidiaries, and affiliates (collectively referred to as “we”, “us”, “our” for the purposes of this section).

The provisions in this section apply to all users (Users are simply referred to below as “you”, “your”, “your”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and for such consumers, these provisions supersede any other terms that may differ or conflict in the Privacy Policy.

This section of the document uses the terms “personal data” (and “sensitive data”) as defined in the VCDPA.

Categories of personal data processed

In this section, we provide a summary of the categories of personal data that we have processed and their purposes. You can read more about these activities in the section entitled “Detailed information about the processing of personal data” in this document..

Categories of personal data that we collect

We collected the following categories of personal data: identifiers, biometric information, internet information, and geolocation data

With your consent, we collect the following categories of sensitive information: consent to access biometric data, precise location permission (not continuous), consent to read health data, and consent to update health data

You can freely give, refuse or withdraw your consent to the processing of sensitive data at any time using the contact details in this document or via the privacy choices link on this Application.

We will not collect any additional categories of personal information without notifying you.

Why we process your personal information

To find out why we process your personal data, you can read the “Detailed information about the processing of personal data” and “The purposes of processing” sections of this document.

We do not process your information for unexpected purposes or for purposes that are incompatible with those originally disclosed without your consent.
You can freely give, refuse or withdraw this consent at any time using the contact details in this document.

How we use the information we collect: sharing your personal information with third parties

We share your personal information with third parties detailed in the section entitled “Detailed information about the processing of personal data” in this document. These third parties are grouped and categorized according to the different processing purposes.
For our purposes, the word “third party” means “a natural or legal person, government agency, or body other than the consumer, controller, processor, or branch of the processor or controller” as defined by the VCDPA.

Selling your personal information

For our purposes, the word “sell” means any “exchange of personal information for monetary compensation by us to a third party” as defined by the VCDPA.
Please note that under the VCDPA, providing personal data to a processor who processes personal data on behalf of a controller is not a sale.
As specified in the “Detailed Information about 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 selling your personal information and how to exercise it

You have the right to opt out of selling your personal information. This means that if you ask us to stop selling your information, we will comply with your request. To fully exercise your right to opt out, you can contact us at any time using the contact details in this document.

We only use any personal information collected from you in connection with the submission of your opt-out request to fulfill the request.

Processing your personal data for targeted advertising

We do not process your personal information for targeted advertising. If we decide to do so, we will inform you in advance and give you the right to opt out of processing your personal information for targeted advertising.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You can exercise certain rights with respect to your data that is processed by us. In particular, you have the right to do the following:

  • access to personal data: the right to know. You have the right to ask us to confirm whether we are processing your personal information. You also have the right to access such personal information.
  • correct incorrect personal information. You have the right to request that we correct any inaccurate personal information that we hold about you, taking into account the nature of the personal information and the purposes of processing the personal information.
  • request the deletion of your personal information. You have the right to ask us to delete all your personal information.
  • obtain a copy of your personal information. We will provide your personal information in a portable and usable format that allows you to easily transfer data to another entity — provided that this is technically possible.
  • opt out of processing your personal information for targeted advertising, the sale of personal information, or profiling to promote decisions that have legal or similarly significant consequences for you.
  • non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means, among other things, that we do not refuse goods or services, charge you a different price, or offer goods or services of a different level or quality just because you have exercised your privacy rights as a consumer. However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and if that personal information or sale is necessary to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by law, we may offer you a different price, rate, level, quality, or selection of goods or services, including offering goods or services free of charge, 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 must submit your request to us by contacting us using the contact details provided in this document.

In order to respond to your request, we need to know who you are.

We will not respond to a request if we are unable to verify your identity with commercially reasonable efforts and therefore confirm that the personal information in our possession actually relates to you. In such cases, we may ask you to provide additional information reasonably necessary to verify you and your request.

If you submit a consumer request, you do not need to create an account with us. However, we may ask you to use your existing account. We will only use any personal information collected from you in connection with your request for authentication purposes, without further disclosing the personal information, keeping it longer than necessary for authentication purposes, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your parental authority.

How and when we are expected to handle your request

We will respond to your request without unnecessary delay, but in all cases and at the latest within 45 days of receipt. If we need more time, we'll explain why and how much more time we need. In this regard, please note that it may take up to 90 days for us to comply with your request.

If we reject your request, we will explain to you the reasons for our rejection without unnecessary delay, but in all cases and no later than 45 days after receiving the request. It is your right to appeal such a decision by submitting a request to us using the information in this document. Within 60 days of receiving the appeal, we will notify 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 dismissed, you can contact the Attorney General to file a complaint.

We do not charge a fee to respond to your request, for a maximum of two requests per year. If your request is clearly unfounded, excessive, or repetitive, we may charge or decline a reasonable fee to comply with the request. In either case, we will communicate our choices and explain the reasons behind them.

Definitions and legal references

Personal Information (or Data)

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

Usage data

Information that is automatically collected through this application (or third-party services used in this application), including: the IP addresses or domain names of the computers used by users using this application, the Uniform Resource Identifier (URI) addresses, the time of the request, the method used to send the request to the server, the size of the file received in response, the numerical code that indicates the status of the response from indicates the server (successful result, error, etc.), the country of origin, the functions of the browser and the operating system used by the user, the different time data per visit (for example, time spent on each page in the application) and details of the path followed within the application, with special attention to the order of the pages visited, and other parameters about the device's operating system and/or IT environment.

User

The person who uses this application and who, unless otherwise stated, coincides with the Data Subject.

Stakeholder

The natural person to whom the personal data refers.

Data Processor (or Data Controller)

The natural or legal person, government agency, agency, or other body that processes personal data on behalf of the controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, government authority, agency or other body that, alone or jointly with others, determines the purposes and means of processing personal data, including the security measures related to the operation and use of this application. Unless otherwise stated, the data controller is the owner of this application.

This application

How the user's personal data is collected and processed.

Service

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

European Union (or EU)

Unless otherwise stated, all references in this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are trackers that consist of small sets of data stored in the user's browser.

Tracker

Tracker indicates any technology, such as cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprints, that can be used to track users, for example by opening or storing information on the user's device.

Legal Information

This privacy statement has been drawn up on the basis of provisions of several laws, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates to this application only, unless otherwise stated in this document.

Last update: April 19, 2023