We are WamBlee s.r.l.

This privacy policy describes how we collect, use and protect your personal information when you use our services.

You can contact us at info@wamblee.it

Table of Contents

  • Introduction
  • Contact information
  • Types of data collected
  • How and where personal data is processed
  • Detailed information on the processing of personal data
  • Further information
  • Your rights under the General Data Protection Regulation (GDPR)
  • Further information if you are based in Switzerland
  • Further information if you are based in Brazil
  • Further information if you are based in California
  • Further information if you are based in Virginia
  • Further information if you are based in Colorado
  • Further information if you are based in Connecticut
  • Further information if you are based in Utah
  • Further information on data processing and collection
  • Definitions and legal references

Introduction

What does this policy contain?
This document explains how this website collects, uses and protects your personal data to achieve the purposes outlined.

What is personal data?
Personal data is information that can be used to identify you directly or indirectly, such as name, surname, email, tracking technologies (such as cookies or tracking pixels), activities and information about the device used. You can find detailed information on the types of data collected in the dedicated sections of this privacy policy or in the messages shown before collection.

Contact information

Address:
Via Vittori 19
48018 Faenza (RA)
Italy

E-mail: info@wamblee.it

Phone: +39 0546 623891

Types of data collected

Personal data collected by this site, independently or through third parties, may include:

  • name;
  • surname;
  • e-mail address;
  • tracking tools;
  • usage data

Full 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 are collected. Personal data may be freely provided by you or, in the case of usage data, collected automatically when using this website. Unless otherwise specified, all data requested by this website is mandatory. Refusal to communicate them may prevent this website from providing its services.

In cases where this website indicates some data as optional, you are free to refrain from communicating such data, without this having any consequence on the availability of the service or on its operation.

Any use of cookies – or other tracking tools – by this website or by the owners of third-party services used by this website has the purpose of providing the service requested by you, in addition to the other purposes described in this document.

You assume responsibility for the personal data of third parties obtained, published or shared through this website.

Methods and place of processing of personal data

Methods of processing

We adopt appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.

In addition to us, in some cases, other parties involved in the organization of this website (administrative, commercial, marketing, legal personnel) may have access to the data.

External parties appointed, if necessary, as data controllers by us may also have access to the data.

You can always request the updated list of these third parties by contacting us using the contact details provided in this document.

Place

The data is processed at our operating offices and in any other place where the parties involved in the processing are located. Your personal data may be transferred to a country other than the one in which you are located. To obtain further information on the place of processing you can refer to the section relating to the details on the processing of personal data.

Retention period

Unless otherwise stated in this document, personal data are processed and stored for the time required by the purpose for which they were collected and may be stored for a longer period due to any legal obligations or on the basis of your consent.

Detailed information on the processing of personal data

Your personal data is collected to allow us to provide our service, comply with our legal obligations, respond to requests or enforcement actions, protect our rights and interests (or yours or third parties), identify any malicious or fraudulent activity, as well as for the purposes indicated below:

Statistics

The services contained in this section allow us to monitor and analyze traffic data and are used to track your behavior.

Google Analytics (Universal Analytics) (Google LLC)

Google Analytics (Universal Analytics) is a statistics service provided by Google LLC (“Google”). Google uses the data collected for the purpose of tracking and examining the use of this website, compiling reports and sharing them with other services developed by Google. Google may use personal data to contextualize and personalize the advertisements of its advertising network.

To learn about Google’s use of data, consult Google’s partner policy and its commercial data page.

Personal data processed: Tracking tools; Usage data

Place of processing: United States

Privacy policy: https://business.safety.google/privacy/

Opt-out link: https://tools.google.com/dlpage/gaoptout

Category of personal information collected under CCPA: information relating to activities on the internet or other networks. This type of processing constitutes: a “sale” pursuant to the CCPA, VCDPA, CPA, CTDPA and UCPA.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this website and interact with them. These services are often called widgets, or small elements inserted into a website or in an application. They provide specific information or perform a particular function and often allow interaction with the user. This type of service may still collect data on web traffic relating to the pages where the service is installed, even when you do not use it.

Google Fonts (Google LLC)

Google Fonts is a font display service managed by Google LLC that allows this website to integrate such content within its pages.

To learn about Google’s use of data, see Google’s partner policy and its commercial data page.

Personal data processed: Tracking tools; Usage data

Place of processing: United States

Privacy policy: https://business.safety.google/privacy/

Opt-out link: https://tools.google.com/dlpage/gaoptout

Category of personal information collected pursuant to CCPA: information relating to activities on the Internet or other networks.

Contacting you

Contact form (this website)

By filling out the contact form with your data, you consent to this website using them to respond to requests for information, quotes, or any other nature indicated by the form header.

Personal data processed: email; name; surname

Category of personal information collected under the CCPA: identifiers. This type of processing constitutes: a “sale of data” (“sale”) under the CCPA, VCDPA, CPA, CTDPA and UCPA.

Further information

Legal basis for processing

We process personal data relating to you if one of the following applies:

  • the processing is necessary for the performance of a contract with you and/or the execution of pre-contractual measures;
  • the processing is necessary for compliance with a legal obligation to which we are the controller;
  • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
  • processing is necessary to pursue our legitimate interest or that of third parties.
  • Processing is necessary to inform Search & Rescue services in the event of detection of one of our previously registered devices.

You can always ask us to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Knowing the duration of storage of your data

When we collect your personal data, we keep it for the time necessary for the purposes for which we collected it. They could be stored for a longer period due to any legal obligations or on the basis of your consent.

Here is what this entails in more detail. We will retain your personal data based on the purposes and reasons indicated below:

  • for contractual purposes: if we have entered into a contract with you, we will retain your data until the performance of that contract is completed.
  • for our legitimate interest: if we use your personal data for operational purposes that are necessary and relevant to our business, we will retain it for as long as necessary for those purposes. You can get more information about these purposes in the relevant sections of this document or by contacting us.
  • with your consent: when the processing is based on your consent, we can retain personal data for a longer period unless you withdraw that consent.
  • legal obligations: we may be required 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, your personal data will be deleted. Therefore, at the end of that period, the right of access, erasure, rectification and the right to data portability can no longer be exercised.

Your rights under the General Data Protection Regulation (GDPR)

You may exercise certain rights with respect to your data processed by us. In particular, to the extent permitted by law, you have the right to:

  • Withdraw your consent at any time. You may withdraw consent to the processing of your personal data that you have previously given.
  • Object to the processing of your data. You may object to the processing of your data when it is carried out on a legal basis other than consent. When personal data is processed in the public interest, by a public authority or to pursue our legitimate interests, you have the right to object to the processing for reasons relating to your particular situation.
  • When personal data is processed for direct marketing purposes, you may object to the processing at any time, free of charge and without providing any reason. In this case, we will stop using your data for marketing. To find out if we use your data for direct marketing purposes, you can refer to the respective sections of this document.
  • Access your data. You have the right to obtain information about the data we process, about certain aspects of the processing and to receive a copy of the data processed.
  • Verify and request rectification. You can verify the accuracy of your data and request its updating or correction.
  • Obtain the limitation of the processing of your data. You can request the limitation of the processing of your data. In this case, we will not process your data for any purpose other than their storage.
  • Obtain the deletion or removal of your personal data. You can request the deletion of your data by us.
  • Receive your data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another controller.
  • File a complaint. You can file a complaint with the competent data protection supervisory authority or take legal action.
  • Know the reason for the data transfer. You have the right to obtain information about the legal basis for the transfer of data abroad including to any international organization governed by international law or consisting of two or more countries, such as the UN.
  • Know the security measures. You have the right to know the security measures we take to protect your data.

How to exercise these rights

Any requests to exercise your rights can be addressed to us. All our contact details are at the beginning of this document.

The request is free of charge and we will respond as soon as possible, in any case within one month, providing you with all the information required by law.

Any rectification, erasure or limitation of processing will be communicated by us to each of the recipients, if any, to whom the personal data have been transmitted, unless this proves impossible or involves a disproportionate effort. We will inform you of these recipients if you request it.

Further information on data processing and collection

Defense in court

Your personal data may be used by us in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this website or related services. You declare that you are aware that we may be obliged to disclose the data by order of the public authorities.

Specific information about your personal data

Upon your request, in addition to the information contained in this privacy policy, this website may provide you with additional and contextual information regarding specific services, or the collection and processing of personal data.

System logs and maintenance

For needs related to operation and maintenance, this website and any third-party services used by it may collect system logs, which are files that record interactions and may also contain personal data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of personal data may be requested from us at any time using the contact details found at the beginning of this document.

Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying you on this page and, if possible, on this website and, if technically and legally feasible, by sending you a notification through one of the contact details in our possession. Therefore, please consult this page frequently, referring to the date of the last modification indicated at the bottom. If the changes affect processing based on your consent, we will collect your consent again, if necessary.

Definitions and legal references

Personal data (or data)

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

Usage data

Usage data means information collected automatically through this website or third-party applications, including IP addresses, browser and operating system characteristics, the time and method of submitting the request, response status, duration of the visit, the sequence of pages visited, and details relating to the device.

This website

The tool by which your personal data is collected and processed.

Service

The service provided by this website as defined in the Terms of Service and on this website.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are tracking tools that consist of small pieces of data stored within your browser.

Tracking tool

A tracking tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows you to be tracked, for example by collecting or saving information on your device.

Legal references

This privacy policy is drafted on the basis of multiple legislative systems. Unless otherwise specified, this privacy policy concerns only this website.

Further information if you reside in California

About this section


This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

Applicability


This section applies to all users (users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the “California Consumer Privacy Act of 2018” (the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Definition


This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act(CCPA/CPRA).

Categories of personal information that we collect

  • We have collected the following categories of personal information about you: 
    • identifiers, and 
    • internet or other electronic network activity information
  • We do not collect sensitive personal information. 
  • We will not collect additional categories of personal information without notifying you.

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


Business Purposes

We may use your personal information to allow the operational functioning of this website and features thereof. In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

Commercial Purposes

We may also use your personal information for other reasons such as for commercial purposes, as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened, or we suffer an actual damage.

No unexpected or incompatible purposes

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?


Unless stated otherwise inside the “Detailed information on the processing of personal data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

What are the sources of the personal information we collect?


We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this website.

Direct Collection: For example, you directly provide your personal information when you submit requests via any forms on this website. 

Indirect Collection: You also provide personal information indirectly when you navigate this website, as personal information about you is automatically observed and collected.

Third Parties: Finally, we may collect your personal information from third parties that work with us in connection with the service or with the functioning of this Application and features thereof.

How we use the information we collect


Disclosing of your personal information with third parties for a business purpose

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

We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA. Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

Opt-Out Rights


We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing. 

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request. To fully exercise your right to opt out, you can contact us at any time using the contact details provided at the start of this document. For a simplified opt-out method you can also use the privacy choices link provided on this website.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

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


The right to access personal information: the right to know and to portability

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

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

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

  • the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
  • the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, considering the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

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

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

  • To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided at the start of this document.
  • For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:
    • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
    • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.
  • Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
  • If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.
  • If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.
  • You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

  • We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
  • We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
  • Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.
  • Should we deny your request, we will explain you the reasons behind our denial.
  • We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Further information if you reside in Virginia


This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to you if you reside in the Commonwealth of Virginia, according to the “Virginia Consumer data Protection Act” (the “VCDPA”), and, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed


You can read about these activities in detail in the section titled “Detailed information on the processing of personal data”within this document.

Types of personal data we collect

  • We have collected the following categories of personal data: identifiers and internet information
  • We do not collect sensitive data.
  • We will not collect additional categories of personal data without notifying you.

Why we process your personal data


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

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent. You can freely give, deny, or withdraw such consent at any time using the contact details provided at the start of this document.

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


We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing. For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.

Sale of your personal data


For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party” as defined by the VCDPA. Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you. As specified in the “Detailed information on the processing of personal data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it


You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided at the start of this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising


We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

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


You may exercise certain rights regarding your data processed by us. You have the right to do the following:

  • access personal data: the right to know. You have the right to request that we confirm whether we are processing your personal data. You also have the right to access such personal data.
  • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, considering the nature of the personal data and the purposes of the processing of the personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — if this is technically feasible.
  • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program. 

How to exercise your rights

  • To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided at the start of this document.
  • For us to respond to your request, we need to know who you are.
  • We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
  • Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
  • If you are an adult, you can make a request on behalf of a child under your parental authority. 

How and when we are expected to handle your request

  • We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
  • Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
  • We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Further information if you reside in Colorado


This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to you if you reside in the State of Colorado, according to the “Colorado Privacy Act” (the “CPA”), and, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CPA.

Categories of personal data processed


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

Categories of personal data we collect

  • We have collected the following categories of personal data: identifiers and internet information
  • We do not collect sensitive data.
  • We will not collect additional categories of personal data without notifying you.

Why we process your personal data


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

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent. You can freely give, deny, or withdraw such consent at any time using the contact details provided at the start of this document.

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


We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the CPA.

Sale of your personal data


As specified in the “Detailed information on the processing of personal data” section of this document, our use of your personal data may be considered a sale under the CPA.

For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the CPA.

Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it


You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided at the start of this document.

For a simplified opt-out method you can also use the privacy choices link provided on this website.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising


We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non-affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CPA. Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer’s request for information or feedback; advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.

Universal opt-out mechanism: Global privacy control


If you want to submit requests to opt-out of the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

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


You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

  • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

  • To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided at the start of this document.
  • For us to respond to your request, we need to know who you are and which right you wish to exercise.
  • We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
  • Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
  • If you are an adult, you can make a request on behalf of a child under your parental authority. 

How and when we are expected to handle your request

  • We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
  • Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
  • We do not charge a fee to respond to your request, for up to two requests per year.

Further information if you reside in Connecticut


This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to you if you reside in the State of Connecticut, according to “An Act Concerning personal data Privacy and Online Monitoring ” (also known as “The Connecticut data Privacy Act” or the “CTDPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CTDPA.

Categories of personal data processed


You can read about these activities in detail in the section titled “Detailed information on the processing of personal data” within this document.

Categories of personal data we collect

  • We have collected the following categories of personal data: identifiers and internet information
  • We do not collect sensitive data.
  • We will not collect additional categories of personal data without notifying you.

Why we process your personal data


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

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent. You can freely give, deny, or withdraw such consent at any time using the contact details provided at the start of this document.

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


We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the CTDPA.

Sale of your personal data


As specified in the “Detailed information on the processing of personal data” section of this document, our use of your personal data may be considered a sale under the CTDPA.

For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it


You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided at the start of this document.

For a simplified opt-out method you can also use the privacy choices link provided on this website.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising


We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non-affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CTDPA. Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own web sites or online applications; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer’s request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.

Universal opt-out mechanism: Global Privacy Control


If you want to submit requests to opt-out of the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

Your privacy rights under the Connecticut Data Privacy Act and how to exercise them


You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data. You have the right to request that we confirm whether we are processing your personal data. You also have the right to access such personal data.

correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, considering the nature of the personal data and the purposes of the processing of the personal data.

request the deletion of your personal data. You have the right to request that we delete any of your personal data.

obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – if this is technically feasible.

opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

  • To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided at the start of this document.
  • For us to respond to your request, we need to know who you are and which right you wish to exercise.
  • We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
  • Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.
  • If you are an adult, you can make a request on behalf of a child under your parental authority.

How and when we are expected to handle your request

  • We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
  • Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.
  • We do not charge a fee to respond to your request, for up to one request per year.

Further information for Utah consumers


This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to you if you reside in the State of Utah, according to the “Consumer Privacy Act” (the “UCPA”), and, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the UCPA.

Categories of personal data processed


You can read about these activities in detail in the section titled “Detailed information on the processing of personal data” within this document.

Categories of personal data we collect

  • We have collected the following categories of personal data: identifiers and internet information
  • We do not collect sensitive data.
  • We will not collect additional categories of personal data without notifying you.

Why we process your personal data


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

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


We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of personal data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word “third party” means “a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor” as defined by the UCPA.

Sale of your personal data


As specified in the “Detailed information on the processing of personal data” section of this document, our use of your personal data may be considered a sale under the UCPA.

For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it


You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided at the start of this document.

For a simplified opt-out method you can also use the privacy choices link provided on this website.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising


We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non-affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by UCPA. Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to a web site or online application; advertisements directed to a consumer in

response to the consumer’s request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”

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


You may exercise certain rights regarding your data processed by us. You have the right to do the following:

access personal data. You have the right to request that we confirm whether we are processing your personal data. You also have the right to access such personal data.

request the deletion of your personal data. You have the right to request that we delete any of your personal data.

obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.

opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

  • To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided at the start of this document.
  • For us to respond to your request, we need to know who you are and which right you wish to exercise.
  • We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.
  • If you are an adult, you can make a request on behalf of a child under your parental authority.

How and when we are expected to handle your request

  • We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
  • Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.
  • We do not charge a fee to respond to your request, for up to one request per year.

Document version: 26/062025