Policy summary

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

    • Advertising

      • AdColony, Amazon Mobile Ads, AppLovin, Fyber, MoPub, ironSource, Unity Ads and Vungle

        Personal Data: Cookies; Usage Data

      • AdMob

        Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

      • Facebook Audience Network

        Personal Data: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

      • Tapjoy, PubMatic and TripleLift

        Personal Data: Tracker; Usage Data

    • Advertising serving infrastructure

      • OpenX Ad Server

        Personal Data: Cookies; Usage Data

    • Analytics

      • Appsee, Appsflyer, Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking, Google Analytics and Twitter Ads conversion tracking

        Personal Data: Cookies; Usage Data

      • Facebook Analytics for Apps

        Personal Data: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service

      • Unity Analytics

        Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

      • Google Analytics for Firebase

        Personal Data: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

    • Contacting the User

      • Mailing list or newsletter and Contact form

        Personal Data: email address; first name; last name

    • Handling payments

      • Google Pay, Apple Pay and Amazon Payments

        Personal Data: various types of Data as specified in the privacy policy of the service

      • Payments processed via the Google Play Store

        Personal Data: device information; payment info; purchase history; Tracker; Usage Data

    • Hosting and backend infrastructure

      • Amazon Web Services (AWS) and Firebase Hosting

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Infrastructure monitoring

      • Crashlytics

        Personal Data: crash data; device information; Universally unique identifier (UUID)

    • Interaction with external social networks and platforms

      • Facebook Like button and social widgets

        Personal Data: Cookies; Usage Data

    • Managing contacts and sending messages

      • Amazon Simple Email Service

        Personal Data: email address

      • OneSignal

        Personal Data: email address; geographic position; language; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service

    • Platform services and hosting

      • Google Play Store

        Personal Data: Usage Data

    • Registration and authentication

      • Facebook Authentication

        Personal Data: Tracker; various types of Data as specified in the privacy policy of the service

      • Google OAuth and Login with Amazon

        Personal Data: various types of Data as specified in the privacy policy of the service

    • Remarketing and behavioral targeting

      • Facebook Custom Audience

        Personal Data: Cookies; email address

      • Facebook Remarketing and Google Ads Remarketing

        Personal Data: Cookies; Usage Data

    • Social features

      • Public profile

        Personal Data: picture; username

    • Traffic optimization and distribution

      • Cloudflare

        Personal Data: Cookies; various types of Data as specified in the privacy policy of the service

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Further information about the processing of Personal Data

    • Push notifications

      This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

      Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
      Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    • Unique device identification

      This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

    • User identification via a universally unique identifier (UUID)

      This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Full policy

Owner and Data Controller

Difference Games LLC

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; first name; last name; username; picture; geographic position; language; device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; launches; operating systems; Universally unique identifier (UUID); crash data; payment info; purchase history.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Advertising, Advertising serving infrastructure, Analytics, Contacting the User, Handling payments, Hosting and backend infrastructure, Interaction with external social networks and platforms, Managing contacts and sending messages, Registration and authentication, Remarketing and behavioral targeting, Social features, Traffic optimization and distribution, Infrastructure monitoring and Platform services and hosting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

  • Advertising

    This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

    AdColony (Jirbo, Inc.)

    AdColony is an advertising service provided by AdColony, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    AdMob (AdMob Google Inc.)

    AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Amazon Mobile Ads (Amazon)

    Amazon Mobile Ads is an advertising service provided by Amazon or by Amazon Europe , depending on how the Owner manages the Data processing.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    AppLovin (AppLovin Corporation)

    AppLovin is an advertising service provided by AppLovin Corporation.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Fyber (SponsorPay GmbH)

    Fyber is an advertising service provided by Fyber N.V.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Germany – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    MoPub (MoPub Inc.)

    MoPub is an advertising service provided by MoPub Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    ironSource (SupersonicAds Ltd.)

    ironSource is an advertising service provided by ironSource Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: UK – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Unity Ads (Unity Technologies ApS)

    Unity Ads is an advertising service provided by Unity Technologies ApS.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Denmark – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Vungle (Vungle, Inc.)

    Vungle is an advertising service provided by Vungle, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Facebook Audience Network (Facebook, Inc.)

    Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

    This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

    Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Tapjoy (Tapjoy, Inc.)

    Tapjoy is an advertising service provided by Tapjoy, Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy PolicyOpt out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    PubMatic (PubMatic, Inc.)

    PubMatic is an advertising service provided by PubMatic, Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    TripleLift (TripleLift, Inc.)

    TripleLift is an advertising service provided by TripleLift, Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy PolicyOpt out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA
  • Advertising serving infrastructure

    This type of service has the purpose of providing an advertising serving infrastructure that enables this Application to maintain its own network that serves optimized and targeted advertisements.
    To this end, the services listed below may allow the Owner to track unique User visits and their navigation patterns, also with the help of Cookies.
    This tracking may occur across different sites or apps, in order to serve optimized and targeted advertisements.

    OpenX Ad Server (OpenX Technologies, Inc.)

    OpenX Ad Server is an advertising server provision service provided by OpenX Technologies, Inc.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA
  • Analytics

    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

    Appsee (Shift 6 Ltd)

    Appsee is an analytics service provided by Shift 6 Ltd.

    This service is designed for mobile apps analytics and can collect various information about the User’s device, highlighted in the Appsee privacy policy.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Israel – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Appsflyer (AppsFlyer Ltd)

    Appsflyer is an analytics service provided by AppsFlyer Ltd.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: Israel – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

    Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Facebook Analytics for Apps (Facebook, Inc.)

    Facebook Analytics for Apps is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing,

    Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Google Ads conversion tracking (Google Inc.)

    Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Application.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Google Analytics (Google Inc.)

    Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Unity Analytics (Unity Technologies ApS)

    Unity Analytics is an analytics service provided by Unity Technologies ApS.

    Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

    Place of processing: Denmark – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Twitter Ads conversion tracking (Twitter, Inc.)

    Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Application.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Google Analytics for Firebase (Google LLC)

    Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
    In order to understand Google's use of Data, consult Google's partner policy.

    Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

    This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

    Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

    Personal Data processed: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users ; operating systems; session duration; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; commercial information; internet information; geolocation data.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
  • Contacting the User

    Mailing list or newsletter (This Application)

    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

    Personal Data processed: email address; first name; last name.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the VCDPA

    Contact form (This Application)

    By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: email address; first name; last name.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the VCDPA
  • Handling payments

    Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
    Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

    Google Pay (Google Inc.)

    Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    Apple Pay (Apple Inc.)

    Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    Amazon Payments (Amazon)

    Amazon Payments is a payment service provided by Amazon.com, Inc., which allows Users to make online payments using their Amazon credentials.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the Amazon privacy policy – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    Payments processed via the Google Play Store (Google LLC)

    This Application uses a payment service provided by Google LLC that allows the Owner to offer the purchase of the app itself or in-app purchases.

    Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

    Personal Data processed: device information; payment info; purchase history; Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: commercial information; internet information.

  • Hosting and backend infrastructure

    This type of service has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Amazon Web Services (AWS) (Amazon)

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

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the Amazon privacy policy – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    Firebase Hosting (Firebase, Inc.)

    Firebase Hosting is a hosting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

  • Infrastructure monitoring

    This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

    Crashlytics (Google LLC)

    Crashlytics is a monitoring service provided by Google LLC.

    Personal Data processed: crash data; device information; Universally unique identifier (UUID).

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers; internet information.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
    The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

    Facebook Like button and social widgets (Facebook, Inc.)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing,

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    Amazon Simple Email Service (Amazon)

    Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

    Personal Data processed: email address.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    OneSignal (Lilomi, Inc.)

    OneSignal is a message sending service provided by Lilomi, Inc.

    OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments. Depending on the permissions granted to this Application, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User's device. This Application uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.

    The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal's use of Data, consult OneSignal's privacy policy.

    Push notifications opt-out
    Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

    Interest-based advertising opt-out
    Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones. Different device configurations, or updates to devices, may affect or change how these indicated settings work.

    Personal Data processed: email address; geographic position; language; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.

    Place of processing: United States – Privacy PolicyOpt out.

    Category of personal information collected according to the CCPA: identifiers; internet information; geolocation data; inferred information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA
  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Google Play Store (Google LLC)

    This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.

    By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

    Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

    Personal Data processed: Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

  • Registration and authentication

    By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
    Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
    Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

    Facebook Authentication (Facebook, Inc.)

    Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

    Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Google OAuth (Google Inc.)

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

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

    Login with Amazon (Amazon)

    Login with Amazon is a registration and authentication service provided by Amazon.com, Inc.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
  • Remarketing and behavioral targeting

    This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

    Facebook Custom Audience (Facebook, Inc.)

    Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Facebook advertising network.

    Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.

    Personal Data processed: Cookies; email address.

    Place of processing: US – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: identifiers; internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Facebook Remarketing (Facebook, Inc.)

    Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Facebook advertising network.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA

    Google Ads Remarketing (Google Inc.)

    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.

    Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.

    Personal Data processed: Cookies; Usage Data.

    Place of processing: US – Privacy PolicyOpt Out.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA
    • a sharing according to the CCPA
    • targeted advertising according to the VCDPA
  • Social features

    Public profile (This Application)

    Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.

    Personal Data processed: picture; username.

    Category of personal information collected according to the CCPA: identifiers; sensorial information.

    This processing constitutes:

    • a sale according to the VCDPA
  • Traffic optimization and distribution

    This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
    Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
    Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

    Cloudflare (Cloudflare)

    Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
    The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.

    Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

    Place of processing: US – Privacy Policy.

    Category of personal information collected according to the CCPA: internet information.

    This processing constitutes:

    • a sale according to the CCPA and the VCDPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Further information about the processing of Personal Data

  • Push notifications

    This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.

    Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
    Users must be aware that disabling push notifications may negatively affect the utility of this Application.

  • Unique device identification

    This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

  • User identification via a universally unique identifier (UUID)

    This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

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

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Owner based within the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

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

The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

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

Notice at collection

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

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information, geolocation data, sensorial information and inferred information.

We have collected the following categories of sensitive personal information: username and payment info

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

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

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

We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.

Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.

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

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

We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.

Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.

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

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

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

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

How long do we keep your personal information?

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

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

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

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.

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

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

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

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

Sale or sharing of your personal information

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

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

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

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

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

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

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. 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 Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

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

The right to correct inaccurate personal information

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

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

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

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

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

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

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

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

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

Information for Virginia consumers

This part 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”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

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

Categories of personal data processed

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

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, sensorial information and inferred information

We do not collect sensitive data.

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

Why we process your personal data

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

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

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

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

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

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

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

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

Processing of your personal data for targeted advertising

For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.

To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

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

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

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

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

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

How to exercise your rights

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

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually 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 minor 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.

Personal Data (or Data)

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

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

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

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

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

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.