Privacy Policy of www.tuurbo.ai

This Application collects some Personal Data from its Users.

This document contains:

• A section dedicated to Users in the United States and their privacy rights
• A section dedicated to Users in Switzerland and their privacy rights
• A section dedicated to Users residing in Brazil and their privacy rights

This document can be printed using the print command in any browser settings.

Data Controller

Tuurbo s.r.l.
Via A. Fleming SNC, Aci Sant’Antonio (CT), 95025
VAT: IT 06099510874

Data Controller’s email address: [email protected]

Types of Data collected

Among the Personal Data collected by this Application, either independently or through third parties, are:

Tracking Tools; Usage Data; financial information; city; postal code; state; province; country; county; latitude (of the city); longitude (of the city); metropolitan area; geographic region; IP address; device information; app information; device logs; operating systems; browser information; language; application launches; number of sessions; session duration; page scroll interactions; mouse movements; scroll position; keypress events; motion sensor events; touch events; video viewing data; clicks; browsing history; search history; session statistics; pageviews; interaction events; page events; custom events; Application opening; email; billing data; first name; last name; phone number; VAT number; company name; profession; workplace; Data communicated while using the service; number of Users; message or email content; City; physical address; purchase history; billing address; website; number of employees; business sector; payment information; order ID; User ID.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the Data collection itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate it, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without any consequence on the availability or operation of the Service.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application.

Methods and place of processing of collected Data

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as third-party technical service providers, postal carriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Place

Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Data Controller.

The User’s Personal Data may be transferred to a country different from the one in which the User is located. To obtain further information about the place of processing, the User can refer to the section on details of Personal Data processing.

Retention period

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on User consent.

Purposes of Data Processing

User Data is collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes:

• Backup saving and management
• Statistics
• Traffic optimization and distribution
• Spam and bot protection
• Remarketing and behavioral targeting
• Advertising
• Hosting and backend infrastructure
• Productivity management
• Displaying content from external platforms
• Tag management
• Interaction with live chat platforms
• User database management
• Contact management and message sending
• Payment processing
• Management of data collection and online surveys
• Interaction with data collection platforms and other third parties

To obtain detailed information on processing purposes and Personal Data processed for each purpose, the User can refer to the “Details on Personal Data processing” section.

Details on Personal Data processing

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

Contact management and message sending

This type of service allows managing a database of email contacts, phone contacts or any other type of contacts, used to communicate with the User. These services may also allow collecting data relating to the date and time the User views messages, as well as User interaction with them, such as information on clicks on links inserted in messages.

HubSpot Email (HubSpot, Inc.)

HubSpot Email is an address management and email sending service provided by HubSpot, Inc.

• Personal Data processed: Usage Data; email; Tracking Tools
• Place of processing: Germany
• Privacy Policy

Mailjet (SAS Mailjet)

Mailjet is an address management and email sending service provided by SAS Mailjet.

• Personal Data processed: last name; email; User ID; country; first name; company name; Tracking Tools
• Place of processing: France
• Privacy Policy

User database management

This type of service allows the Data Controller to build user profiles starting from an email address, name or any other information the User provides to this Application, as well as track User activities through statistical features.

HubSpot CRM (HubSpot, Inc.)

HubSpot CRM is a User database management service provided by HubSpot, Inc.

• Personal Data processed: City; last name; purchase history; Usage Data; email; physical address; country; first name; phone number; profession; company name; various types of Data as specified by the service’s privacy policy
• Place of processing: Germany
• Privacy Policy

Payment processing

Unless otherwise specified, this Application processes all credit card, bank transfer or other payments through external payment service providers.

Stripe (Stripe Technology Europe Ltd)

Stripe is a payment service provided by Stripe Technology Europe Ltd.

• Personal Data processed: last name; purchase history; email; billing address; first name
• Place of processing: European Union
• Privacy Policy

PayPal (Paypal)

PayPal is a payment service provided by PayPal Inc., which allows the User to make online payments.

• Personal Data processed: last name; purchase history; email; order ID; billing address; payment information; first name; phone number; company name
• Place of processing: See Paypal’s privacy policy
• Privacy Policy

Tag management

This type of service is functional to the centralized management of tags or scripts used on this Application.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy

Productivity management

This type of service helps the Data Controller manage tasks, work projects and generally productivity-related activities.

Gmail (Google Ireland Limited)

Gmail is an email communication management service provided by Google Ireland Limited.

• Personal Data processed: last name; Data communicated while using the service; Usage Data; email; country; first name; phone number; VAT number; profession; company name; workplace
• Place of processing: Ireland
• Privacy Policy

Google Sheets (Google LLC)

Google Sheets is an online spreadsheet writing and work process management service provided by Google LLC.

• Personal Data processed: postal code; city; last name; Data communicated while using the service; Usage Data; email; country; first name; phone number; VAT number; profession; company name; workplace
• Place of processing: United States
• Privacy Policy

Management of data collection and online surveys

This type of service allows this Application to manage the creation, implementation, administration, distribution and analysis of forms and online surveys.

Typeform (TYPEFORM S.L)

Typeform is a form generator and data collection platform provided by TYPEFORM S.L.

• Personal Data processed: last name; Data communicated while using the service; Usage Data; email; physical address; country; first name; number of employees; phone number; VAT number; profession; company name; website; various types of Data
• Place of processing: Spain
• Privacy Policy

Hosting and backend infrastructure

Fattura24 (Fattura24 SRL)

Fattura24 is an invoicing and accounting management service provided by Fattura24 SRL.

• Personal Data processed: billing data
• Place of processing: Italy
• Privacy Policy

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 by the service’s privacy policy
• Place of processing: Italy
• Privacy Policy

Amazon S3 (Amazon Web Services, Inc.)

Amazon S3 is a cloud storage service provided by Amazon Web Services, Inc.

• Personal Data processed: Usage Data
• Place of processing: United States
• Privacy Policy

Interaction with live chat platforms

HubSpot Chat (HubSpot, Inc.)

HubSpot Chat is a service for interaction with the HubSpot live chat platform, provided by HubSpot, Inc.

• Personal Data processed: message or email content; email
• Place of processing: Germany
• Privacy Policy

Interaction with data collection platforms and other third parties

Typeform Widget (TYPEFORM S.L)

The Typeform widget is a service that allows interaction with the Typeform data collection platform managed by TYPEFORM S.L.

• Personal Data processed: city; last name; Data communicated while using the service; Usage Data; email; billing address; country; first name; number of employees; phone number; VAT number; profession; company name; workplace; business sector; website; state
• Place of processing: Spain
• Privacy Policy

Traffic optimization and distribution

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

• Personal Data processed: Tracking Tools
• Place of processing: United States
• Privacy Policy

Spam and bot protection

Cloudflare Bot Management (Cloudflare Inc.)

Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare Inc.

• Personal Data processed: Application opening; metropolitan area; postal code; city; clicks; county; search history; browsing history; Usage Data; video viewing data; session duration; interaction events; page events; keypress events; custom events; motion sensor events; touch events; browser information; device information; app information; page scroll interactions; IP address; application launches; latitude (of the city); language; device logs; longitude (of the city); mouse movements; country; number of sessions; pageviews; scroll position; province; geographic region; operating systems; session statistics; state; Tracking Tools
• Place of processing: United States
• Privacy Policy

Advertising

Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy
• Opt out

LinkedIn Ads (LinkedIn Ireland Unlimited Company)

LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy

LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

LinkedIn conversion tracking (LinkedIn Insight Tag) is a statistics and behavioral targeting service provided by LinkedIn Corporation.

• Personal Data processed: Usage Data; device information; Tracking Tools
• Place of processing: United States
• Privacy Policy

Google Ads conversion tracking (Google Ireland Limited)

Google Ads conversion tracking is a statistics service provided by Google Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy

Google Ad Manager (Google Ireland Limited)

Google Ad Manager is an advertising service provided by Google Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy

Remarketing and behavioral targeting

Facebook Remarketing (Meta Platforms Ireland Limited)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy
• Opt Out

Meta Custom Audiences (Meta Platforms Ireland Limited)

Meta Custom Audiences is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited.

• Personal Data processed: email; Tracking Tools
• Place of processing: Ireland
• Privacy Policy
• Opt out

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: United States
• Privacy Policy
• Opt Out

Google Ads Remarketing (Google Ireland Limited)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy
• Opt Out

Backup saving and management

Google Drive Backup (Google Ireland Limited)

Google Drive is a backup saving and management service provided by Google Ireland Limited.

• Personal Data processed: various types of Data as specified by the service’s privacy policy
• Place of processing: Ireland
• Privacy Policy

Statistics

ChartMogul (ChartMogul Ltd)

ChartMogul is a statistics service provided by ChartMogul Ltd.

• Personal Data processed: Usage Data; financial information; Tracking Tools
• Place of processing: Germany
• Privacy Policy

Cloudflare Web Analytics (Cloudflare Inc.)

Cloudflare Web Analytics is an anonymized statistics service provided by Cloudflare Inc.

• Personal Data processed: Usage Data; device information; language
• Place of processing: United States
• Privacy Policy

Google Analytics 4 (Google Ireland Limited)

Google Analytics is a statistics service provided by Google Ireland Limited.

• Personal Data processed: Usage Data; number of Users; session statistics; Tracking Tools
• Place of processing: Ireland
• Privacy Policy
• Opt Out

Displaying content from external platforms

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service managed by Google Ireland Limited.

• Personal Data processed: Usage Data; Tracking Tools
• Place of processing: Ireland
• Privacy Policy

Information on how to opt out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users can learn more about how to opt out of interest-based advertising in the appropriate section of the Cookie Policy.

Cookie Policy

This Application makes use of Tracking Tools. To learn more, Users can consult the Cookie Policy.

Additional information for users

Legal basis of processing

The Data Controller processes Personal Data relating to the User if one of the following applies:

• the User has given consent for one or more specific purposes
• processing is necessary for the performance of a contract with the User and/or pre-contractual measures
• processing is necessary to comply with a legal obligation to which the Data Controller is subject
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller
• processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party

It is always possible to request the Data Controller to clarify the specific legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Additional information on retention time

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on User consent.

Therefore:

• Personal Data collected for purposes connected to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed
• Personal Data collected for purposes related to the Data Controller’s legitimate interests will be retained until such interest is satisfied

When processing is based on User consent, the Data Controller may retain Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon expiry of this period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.

User rights under the General Data Protection Regulation (GDPR)

Users may exercise certain rights with respect to Data processed by the Data Controller.

In particular, within the limits provided by law, the User has the right to:

• withdraw consent at any time. The User can revoke consent to the processing of their Personal Data previously expressed
• object to processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent
• access their Data. The User has the right to obtain information on Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed
• verify and request rectification. The User can verify the correctness of their Data and request its updating or correction
• obtain restriction of processing. The User can request restriction of processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than their storage
• obtain deletion or removal of their Personal Data. The User can request deletion of their Data by the Data Controller
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action

Users have the right to obtain information regarding the legal basis for data transfer abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to processing for reasons connected to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they can object to processing at any time, free of charge and without providing any reason. If Users object to processing for direct marketing purposes, Personal Data will no longer be processed for such purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. The request is free and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all information required by law. Any rectifications, deletions or restrictions of processing will be communicated by the Data Controller to each recipient, if any, to whom the Personal Data was transmitted, unless this proves impossible or involves disproportionate effort. The Data Controller communicates such recipients to the User if requested.

Additional information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, processing purposes, categories of personal data recipients, if any, retention period and other information on Personal Data can be found in the section entitled “Detailed information on Personal Data processing” within this document.

User rights under the Federal Act on Data Protection

Users may exercise certain rights relating to their data within the limits of the law, including the following:

• right of access to Personal Data
• the right to object to the processing of their Personal Data (which also allows Users to request restriction of processing of Personal Data, deletion or destruction of Personal Data, prohibition of disclosure of Personal Data to third parties)
• right to receive their Personal Data and transfer it to another data controller (data portability)
• right to request rectification of incorrect Personal Data

How to exercise these rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. Such requests are free and the Data Controller will respond as soon as possible, providing Users with the information required by law.

Additional information for Users in Brazil

This section of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Application and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “our”).

This section applies to all Users in Brazil (such Users are referred to below simply as “you”, “your”), pursuant to the “Lei Geral de Proteção de Dados” and, for such Users, prevails over any other possibly divergent or conflicting information contained in this privacy policy.

In this part of the document, the term “personal information” is used as defined by LGPD.

Legal bases under which we process your personal information

We process your personal information only if one of the legal bases for such processing exists. The legal bases are as follows:

• your consent to the processing activities in question
• compliance with legal obligations that we are required to satisfy
• execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments
• studies conducted by research entities, preferably carried out on anonymized personal information
• performance of a contract and related pre-contractual measures, should you be party to such contract
• exercise of our rights in court, in administrative proceedings or in arbitration
• protection or physical safety of you or a third party
• health protection – in the context of procedures implemented by health entities or professionals
• our legitimate interest, provided that your fundamental rights and freedoms do not prevail over such interests
• credit protection

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

Categories of personal information processed

To find out which categories of personal information are processed, you can refer to the “Details on Personal Data processing” section in this document.

Why we process your personal information

To find out why we process your personal information, refer to the “Details on Personal Data processing” and “Purposes of Data Processing” sections in this document.

Your privacy rights in Brazil, how to submit a request and how we will handle it

Your privacy rights in Brazil

You have the right to:

• obtain confirmation of the existence of processing activities concerning your personal information
• access your personal information
• obtain rectification of incomplete, inaccurate or outdated personal information
• obtain anonymization, blocking or deletion of unnecessary or excessive personal information, or information that is processed in violation of LGPD provisions
• obtain information regarding the possibility of giving or refusing your consent and the related consequences
• obtain information regarding third parties with whom we share your personal information
• obtain, following your explicit request, portability of your personal information (except anonymized information) to other product or service providers, provided that our trade and industrial secrets are safeguarded
• obtain deletion of processed personal information if processing was carried out on the basis of your consent, unless one or more of the exceptions provided by Article 16 LGPD applies
• revoke your consent at any time
• file a complaint regarding your personal information with ANPD (National Data Protection Authority) or a consumer protection body
• object to processing activities in cases where such processing is not carried out in compliance with legal provisions
• request clear and adequate information regarding criteria and procedures used in automated decision-making processes
• request review of decisions that harm your interests, made solely on the basis of automated decision-making processes of your personal information

You will never be discriminated against, nor will you in any way suffer any treatment that is unfavorable to you, as a result of exercising your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and how long we will handle your request

We will do our best to respond to your request as soon as possible.

In any case, if it were impossible for us to do so, we will ensure we communicate to you the factual or legal reasons that prevent us from immediately satisfying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the natural or legal person to whom you should address your requests.

Should you decide to submit an access request or a request for confirmation of the existence of processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.

You must also let us know if you want an immediate response, in which case you will receive a simplified response, or if you need a complete disclosure.

In the latter case, we will respond within 15 days from the time of your request, providing you with all information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all criteria used for processing and the purposes of such processing, while safeguarding our trade and industrial secrets.

Should you decide to submit a request for rectification, deletion, anonymization or blocking of personal information, we will ensure we immediately inform other parties with whom we have shared your personal information of your request so that they can in turn satisfy your request – except in cases where such communication proves impossible or excessively burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as provided by the instruments made available by international law
• when the transfer is necessary to defend the life or physical safety of you or third parties
• when the transfer is authorized by ANPD
• when the transfer derives from an obligation assumed in the context of an international cooperation agreement
• when the transfer is necessary for the exercise of a public order or for the performance of a public service
• when the transfer is necessary to comply with a legal obligation, performance of a contract and related pre-contractual measures, or the normal exercise of rights in court, administrative proceedings or arbitration

Additional information for Users in the United States

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the company that manages this Application and, where applicable, by its parent company, its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “our”).

The information contained in this section applies to all Users (referred to below simply as “you”, “your”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provision contained in the privacy policy.

This part of the document uses the term Personal Information (and Sensitive Personal Information).

Notice at collection

The following Notice at collection provides timely information on categories of Personal Information collected or disclosed in the last 12 months so that you can exercise meaningful control over the use of such Information.

Categories of Personal Information collected

Identifiers

• Data processed: various types of Data; city; postal code; state; province; country; IP address; device information; email; first name; last name; phone number; company name; profession; VAT number; message content
• Purposes: Backup saving and management, Spam and bot protection, Remarketing, Productivity management, Database management, Contact management, Payment processing, Data collection management, Hosting and backend infrastructure
• Sale or Sharing: Yes
• Targeted Advertising: Yes

Personal information

• Data processed: Tracking Tools; Usage Data; financial information
• Purposes: Statistics
• Sale or Sharing: Yes
• Targeted Advertising: Yes

Internet activity information

• Data processed: Tracking Tools; Usage Data; city; device information; browsing history; session statistics; email
• Purposes: Statistics, Traffic optimization, Spam and bot protection, Remarketing, Advertising, Productivity management, Tag management
• Sale or Sharing: Yes
• Targeted Advertising: Yes

Geolocation data

• Data processed: city; postal code; state; province; country; latitude; longitude; metropolitan area; geographic region; IP address
• Purposes: Spam and bot protection
• Sale or Sharing: Yes
• Targeted Advertising: Yes

Commercial information

• Data processed: billing data; first name; last name; email; purchase history; billing address; payment information
• Purposes: Hosting and backend infrastructure, Productivity management, Payment processing
• Sale or Sharing: Yes
• Targeted Advertising: Yes

Your privacy rights under US state laws

You may exercise certain rights relating to your Personal Information. In particular, to the extent permitted by applicable law, you have:

• the right to access Personal Information: the right to know. You have the right to request that we confirm whether we are processing your Personal Information. You also have the right to access such Personal Information
• the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you
• the right to request deletion of your Personal Information. You have the right to request that we delete any of your Personal Information
• the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format
• the right to opt out of Sale of your Personal Information
• the right to non-discrimination

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

• The right to opt out of Sharing of your Personal Information for cross-context behavioral advertising
• The right to request to limit our use or disclosure of your Sensitive Personal Information only to what is necessary to perform services or provide goods

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in these states you have:

• The right to opt out of processing of your personal information for Targeted Advertising or profiling for purposes of decisions that produce legal or similarly significant effects concerning you
• The right to give, deny or freely withdraw your consent to the processing of your Sensitive Personal Information

In Minnesota and Maryland, Users also have the right to obtain a list of specific third parties to which the controller has disclosed the consumer’s personal data.

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

• The right to opt out of processing of your Personal Information for Targeted Advertising
• The right to opt out of processing of your Sensitive Personal Information

How to exercise your privacy rights under US state laws

To exercise the rights described above, you must submit your request by contacting us through the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity.

How to exercise your opt-out rights

In addition to what is indicated above, to exercise your right to opt out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.

If you wish to submit opt-out requests for Sale or Sharing and Targeted Advertising activities through a user-enabled global privacy control, such as the Global Privacy Control (“GPC“), you are free to do so and we will respect such request without hindrance.

How and when we expect to handle your request

We will respond to your request without undue delay, but in any case within the timeframes required by applicable law. If we need more time, we will explain the reasons and how much more time we need.

If we deny your request, we will explain the reasons behind our refusal (where provided by applicable law, you can then contact the competent authority to file a complaint).

We do not charge any fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where permitted by applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In both cases, we will communicate our choices and explain the reasons.

Additional information on processing

Legal defense

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for defense against abuse in the use of this Application or related Services by the User.

The User declares to be aware that the Data Controller may be required to disclose the Data by order of public authorities.

Specific information

Upon request by the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance needs, this Application and any third-party services it uses may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Additional information relating to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, where possible, on this Application as well as, where technically and legally feasible, sending a notification to Users through one of the contact details in its possession. It is therefore recommended to consult this page frequently, referring to the date of last modification indicated at the bottom.

Should the changes affect processing for which the legal basis is consent, the Data Controller will collect new consent from the User, if necessary.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Personal data means any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Sensitive Personal Information

Sensitive Personal Information means all Personal Information that is not publicly available and that reveals information considered sensitive under applicable privacy regulations.

Usage Data

This is information collected automatically through this Application (also from third-party applications integrated into this Application), including: IP addresses or domain names of computers used by the User connecting to this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the features of the browser and operating system used by the visitor, the various time characteristics of the visit (e.g., the time spent on each page) and details about the path followed within the Application.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal entity, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, alone or together with others, determines the purposes and means of processing personal data and the tools adopted, including security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which Users’ Personal Data is collected and processed.

Service

The Service provided by this Application as defined in the related terms (if present) on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, in exchange for money or for other valuable consideration, as defined by applicable US state privacy legislation.

Sharing

Sharing means any sharing, rental, release, disclosure, dissemination, making available, transfer or other communication verbally, in writing or by electronic or other means, of a consumer’s Personal Information by the company to a third party for cross-context behavioral advertising.

Targeted Advertising

Targeted Advertising means the display of advertising to a consumer for which the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across non-affiliated websites or online applications to predict such consumer’s preferences or interests.

European Union (or EU)

Unless otherwise specified, all references to the European Union contained in this document are intended to include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools consisting of small portions of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables tracking of Users, for example by collecting or saving information on the User’s device.

Legal references

This privacy policy is drawn up based on multiple legislative systems.

Unless otherwise specified, this privacy policy concerns exclusively this Application.

Last modified: February 28, 2025