- Vidergy

Privacy Policy

This is the Privacy Policy (“Policy”) of Vidergy Networks LLC (“Vidergy,” “Our,” “Us,” or “We”).

I. We are:

Vidergy Networks LLC,

9150 Belvedere Rd. Suite #106,

Royal Palm Beach, FL 33411, U.S.A.

Email: Legal@Vidergy.com

Vidergy is a Limited Liability Company

Vidergy is organized under the laws of Florida, U.S.A.

Vidergy is the Data Controller and Owner in this Policy.

This is the Privacy Policy (“Policy”) of Vidergy Networks LLC (“Vidergy,” “Our,” “Us,” or “We”).

II. Your Agreement:

We collect some Personal Data from Users of Our Network Connected Services (“You” or “Your”).
This Policy sets forth:
1. Privacy related terms and conditions that govern Your use of Our Network Connected Services; and
2. The rights You have with respect to Your use of Our Network Connected Services.
You must cease all of Your access and use of Our Network Connected Services if:
1. You do not accept the privacy related terms and conditions that govern Your use of Our Network Connected Services; and/or
2. You demand more or different rights with respect to Your use of Our network connected services than We have set forth in this Policy or that are otherwise granted to You under the prevailing law where You use Our Network Connected Services.
BY CONTINUING YOUR USE OF OUR NETWORK CONNECTED SERVICES, YOU ACCEPT THIS PRIVACY POLICY, WHICH MAY CHANGE FROM TIME TO TIME, BUT WHICH WILL REMAIN ACCESSIBLE THROUGH THE SPECIFIC NETWORK CONNECTED SERVICES YOU ACCESS AND USE.

III. Summary of Personal Data We collect and/or process for the following services:

Analytics:
1. Google Analytics
2. Personal Data: Tracker; Usage Data.
Displaying content from external platforms
1. Google Fonts : Personal Data: Usage Data: various types of Data as specified in the privacy policy of the service
2. Gravatar : Personal Data: email address; Usage Data
3. YouTube video widget (Privacy Enhanced Mode) : Personal Data: Trackers; Universally unique identifier (UUID); Usage Data
Tag Management
1. Google Tag Manager : Personal Data: Usage Data

IV. Organization of this Policy:

This Policy contains several sections that are directed to all jurisdictions.
This Policy contains several sub-sections that supplement or amend this Policy in various expressly named jurisdictions.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the Country of Brazil.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the State of California, U.S.A.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the State of Colorado, U.S.A.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the State of Florida, U.S.A.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the State of Virginia, U.S.A.
This Policy contains a sub-section dedicated to Users of Our Network Connected Services in the State of Washington, U.S.A.
Add Texas.
Add Oregon.
Add Connecticut (CTDPA – 2022).
Add Utah (UCPA – 2023).
TBD.
TBD.
TBD.
TBD.
TBD.
2.16

Definitions and Legal References.
1. “Application” means this Network Connected Service owned or otherwise controlled by Us
2. “Cookie” means a Tracker consisting of one or more small sets of data stored in, or otherwise in association with, the User’s browser.
3. “Channel Partner” means a Person authorized by Vidergy to Resell Vidergy Products to Venue Partners.
4. “Data Controller” (or “Owner”) means the Person that alone or jointly with others determines the purposes and means of processing Personal Data, including the security measures used to protect the operation and use of this Network Connected Service. Vidergy is the Data Controller and Owner of this Network Connected Service.
5. “Data Processor” means the Persons that process Personal Data on Our behalf as described in this Policy.
6. “Data Subject” means the natural person to whom the Personal Data refers.
7. “End User” is the Venue Partner that provides access to Products and/or Services in a Venue for interactive use by Power Requestors and/or Power Consumers.
8. “European Union” and “EU” means 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.
9. “Internal Use” is any business use of a Product and/or Service that includes providing access to the Products and/or Services in a Venue for interactive use by Power Requestors and/or Power Consumers. For the avoidance of doubt, “Internal Use” excludes any Resale to an unaffiliated third-party, downstream Channel Partner, or downstream Venue Partner.
10. “Network Connected Services” means the: (i) Vidergy Commercial Website; (ii) the Vidergy Dashboard available to Vidergy’s Channel Partners and Vidergy’s Venue Partners; and (iii) the Energy-as-a-Service (EaaS) operational and advertising servers accessible via the web browsers of the smart devices of Vidergy’s Power Requestors and Vidergy’s Power Consumers; that include the means by which Your Personal Data is collected.
11. “Person” means an individual, a partnership, a corporation, a limited liability company, an association, a joint stock company, a trust, a joint venture, an unincorporated organization, association or other entity, or a Governmental Authority.
12. “Personal Data” and “Data” mean 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.
13. “Power Consumer” is the Person who’s device receives power provided at a hardware product provided by Vidergy such as, but not limited to, a Vidergy Duplex outlet.
14. “Power Requestor” is the Person who’s smart device: (i) engages with a Vidergy service; and (ii) receives advertising or performs one or more other actions to cause an enablement of power for a limited duration of time at a hardware product provided by Vidergy such as, but not limited to, a Vidergy Duplex outlet.
15. “Products” means the hardware products, Software, and related documentation that Vidergy makes available to Vidergy’s Channel Partners for Resale (or, in the case of Software, license grant to use such Software) and Vidergy’s Venue Partners for installation and operation, as such may be updated from time to time.
16. “Resale” or “Resell” includes any of the following: (i) sales to an End User; (ii) delivery to an End User;
  1. installation in a Venue; or (iv) other dispositions of a Product or Service authorized by Vidergy, in exchange for monetary or non-monetary consideration, the sufficiency of which is acknowledged by the Parties or parties in privity, and, as the case may be:
  2. transfer of title (or, for Software, a license conferring the right to use the Software, and, for Services, the entitlement to receive such Services) to the End User of such Product or Service; or transfer of title (or, for Software, a license conferring the right to use the Software, and, for Services, the entitlement to receive such Services) to an intermediary where the Product or Service is or will be used by an unaffiliated Power Requestor and/or Power Consumer. Examples of such intermediaries include, but are not limited to, a financial intermediary such as a leasing company, even if such leasing company is affiliated with the Valued Partner, a service provider such as a vendor in an establishment of public accommodation, and the like.“Service” or “Services” means one or more services that Vidergy offers for sale to its customers or others in whole or in part by this Network Connected Service as described in the relative terms (if available) and on this site/application.

“Software” is the machine-readable (object code) version of computer programs developed or marketed by Vidergy, including firmware and any related documentation. For the avoidance of any doubt, Software expressly excludes source code unless such source code is separately identified as such with particularity in a Resale agreement, Resell agreement, or Services agreement.
“Tracker” means indicates any technology (e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, fingerprinting, and the like) that enables the tracking of Users, for example by accessing or storing information on the User’s device.
“URI” means a Uniform Resource Identifier.
“Usage Data” means information collected automatically through this Network Connected Service or third- party services employed in cooperation with this Network Connected Service, which can include: the IP addresses or domain names of the computers utilized by the Users who use this Network Connected Service, the URI addresses, 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 response (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 information technology environment.
“User” means You or the individual natural person You authorize who is using this Network Connected Service, and who, unless otherwise specified, coincides with the Data Subject. In this Policy, a smart device associated with the User is a surrogate for the User wherein “smart device” with respect to a User shall mean at least one computing device such as, but not limited to, a fixed computer, a portable computer, a tablet computer, a telephonic device (e.g., a cell phone, a smart phone, some other device capable of voice communication, or some other internet-capable device), an internet device, a wearable computing device, a vehicle-based computing device, and the like).
“Venue” means any physical place authorized by Vidergy to host at least one Vidergy Product.
“Venue Partner” means any Person who controls a Venue wherein “control” with respect to a Venue shall mean the Person having or otherwise claiming or exhibiting legal authority to permit, install, or direct the installation of Vidergy Products.
“Vidergy Commercial Website” means the publicly-accessible internet website controlled by Vidergy and accessible at https://vidergy.com.
“Vidergy Dashboard” means the private internet website accessible to credentialed account holders, typically Vidergy’s Channel Partners and Vidergy’s Venue Partners, which is controlled by Vidergy and accessible at https://vidergy.net.

Types of Data collected.
1. Among the types of Personal Data that this Network Connected Service collects, by itself or through third parties, there are:
  1. Tracker-collected data;
  2. Usage Data;
  3. email address; and
  4. Universally unique identifier (UUID).

Complete details on each type of Personal Data collected are provided in the dedicated sub-sections of this Policy or by specific explanation texts displayed or otherwise presented to the User 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 Network Connected Service.
Unless otherwise specified, all Data requested by this Network Connected Service is mandatory and failure to provide this Data may make it impossible for this Network Connected Service to provide its services.
1. In cases where this Network Connected Service 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.
2. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
3. Use of Cookies or other tracking tools by this Network Connected Service or by the owners of third-party services used by this Network Connected Service enables the provision of services requested and required by the User, in addition to any other purposes described in this Policy and in a Cookie Policy if such policy is available.
4. Our Cookie Policy for this Network Connected Services in Section Section XI “Cookie Policy” of this Policy.
You are responsible for any third-party Personal Data obtained, published, or shared by You or anyone You authorize through this Network Connected Service, and You confirm You have the third party’s consent to provide this Data to Us and/or others.

VII. Mode and place of processing the Data.

Methods of processing:
1. We and Our Data Processors take commercially reasonable security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
2. We and Our Data Processors carry out Data processing using computers and/or IT enabled tools while following organizational procedures and modes strictly related to the purposes indicated.
3. In addition to Us and Our Data Processors, in some cases, Your Data may be accessible to certain types of persons in charge of or otherwise involved with the operation of this Network Connected Service such as, but not limited to, administration, sales, marketing, legal, and system administration parties associated with Us or the parties we contract with.
4. In addition to Us and Our Data Processors, in some cases, Your Data may be accessible to external parties such as, but not limited to, third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies associated with Us or the parties we contract with.
5. A current list of these parties may be requested from Us or Our Data Processors at any time.
Legal basis of processing:
1. We and Our Data Processors may process Personal Data relating to Users if one of the following applies:
  1. Users have given their consent for one or more specific purposes:
    - Under some legislations Us and Our Data Processors are allowed to process Personal Data until the User objects to such processing (“opts-out”), without having to rely on consent or any other
    - 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 We or Our Data Processors are subject;
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Us or Our Data Processors; and
Processing is necessary for the purposes of the legitimate interests pursued by Us or Our Data Processors or by a third party.

2.2 You may request Our help clarifying the specific legal basis that applies to the processing of Your Personal Data and in particular whether Your provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place:
1. Data related to Users is processed at Our operating offices and/or in any other places where We, Our Data Processors, third-parties we hire, or our respective computing servers that are involved in the processing are located.
2. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.
  1. You may request Our help to determine where Your Personal Data is processed; and
  2. You may find out more about the place of processing transferred Data by checking the relevant jurisdictional sub-section of this Policy containing details about processing Personal Data.
3. Users are 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 Us and Our Data Processors to safeguard such Data.
Retention time:
1. Personal Data shall be processed and stored for as long as required by the purpose such Data has been collected for.
2. Therefore:
  1. Personal Data collected for purposes related to the performance of a contract between Us or Our Data Processors and the User shall be retained until such contract has been fully performed.
  2. Personal Data collected for the purposes of Our or Our Data Processor’s legitimate interests shall be retained as long as needed to fulfill such purposes.
  3. You may request Our help to identify the legitimate interests pursued by Us or Our Data Processors if such specific information is not within the relevant jurisdictional sub-sections of this Policy.
3. We and Our Data Processors 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, We and Our Data Processors 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.
4. Once the retention period expires, the User’s Personal Data shall be deleted.

4.5 The User’s right of access, right to erasure, right to rectification, and right to data portability cannot be enforced after expiration of the retention period.

VIII. The purposes of processing.

Data concerning the User is collected to:
1. Allow Us and Our Data Processor to provide services related to the Network Connected Service
2. Allow Us and Our Data Processor to comply with our legal obligations;
3. Allow Us and Our Data Processor to respond to enforcement requests;
4. Allow Us and Our Data Processor to protect our rights and interests or the rights and interests of other Users or third parties;
5. Allow Us and Our Data Processor to detect malicious or fraudulent activity; and
6. Allow Us and Our Data Processor to perform any one or more of the services described in Section IX “Detailed information on the processing of Personal Data” in this Policy.

Detailed information on the processing of Personal Data.
1. Personal Data is collected for the purposes described in this Section IX.
2. Personal Data is collected using the services described in this Section IX.
3. Analytics – Vidergy
  1. The services contained in this section enable Us and Our Data Processors to monitor and analyze network traffic.
  2. The services contained in this section can be used to keep track of User behavior.
  3. Vidergy Analytics (Vidergy Advertising LLC)
    1. Vidergy Analytics is a network analysis service provided by Vidergy Networks LLC (“Vidergy Networks”).
    2. Vidergy Networks utilizes Data collected to track and examine the use of this Network Connected Service, to prepare reports on its activities, and share them with other Vidergy Networks services.
    3. Vidergy Networks may use Data collected to contextualize and personalize ads of its own advertising network.
  4. Personal Data processed:
    1. Trackers;
    2. Universally Unique Identifier (UUID); and
    3. Usage Data.
  5. Place of Processing:
    1. U.S.A.
  6. Opt-out:
    1. Contact Us at the contact information provided in this Policy; and(b) Cease all use of this Network Connected Service.

1. Storage Duration:
  1. AMP_TOKEN: 1 hour
  2. _ga: 2 years
  3. _gac*: 3 months
  4. _gat: 1 minute
  5. _gid: 1 day
2. Category of personal information collected according to the CCPA:
  1. internet information.
3. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.

Analytics – Google
1. The services contained in this section enable Us and Our Data Processors to monitor and analyze network traffic.
2. The services contained in this section can be used to keep track of User behavior.
3. Google Analytics (Google LLC)
  1. Google Analytics is a network analysis service provided by Google LLC (“Google”).
  2. Google utilizes Data collected to track and examine the use of this Network Connected Service, to prepare reports on its activities, and share them with other Google services.
  3. Google may use Data collected to contextualize and personalize ads of its own advertising network.
4. Personal Data processed:
  1. Tracker;
  2. Usage Data.
5. Place of Processing:
  1. U.S.A.
  2. Google Privacy Policy.
6. Opt-out:
  1. Google Opt Out; and
  2. Cease all use of this Network Connected Service.
7. Storage Duration:
  1. AMP_TOKEN: 1 hour
  2. _ga: 2 years
  3. _gac*: 3 months

_gat: 1 minute
_gid: 1 day

1. Category of personal information collected according to the CCPA:
  1. internet information.
2. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.

Displaying Content From External Platforms – Google Fonts
1. This type of service allows Users to view content hosted on external platforms directly in the User’s browser or from the pages of this Network Connected Service and interact with them.
2. This service might still collect network traffic data for pages where the service is installed, even when Users do not use it.
3. Google Fonts (Google LLC)
  1. Google Fonts is a typeface visualization service provided by Google LLC that allows this Network Connected Service to incorporate content of this kind on its pages or in the User’s browser.
4. Personal Data processed:
  1. Usage Data; and
  2. Various types of Data as specified in this Policy and/or the privacy policy of the service.
5. Place of Processing:
  1. U.S.A.
  2. Google Privacy Policy.
6. Category of personal information collected according to the CCPA:
  1. internet information.
7. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.
Displaying Content From External Platforms – Vidergy
1. This type of service allows Users to view content hosted on external platforms directly in the User’s browser or from the pages of this Network Connected Service and interact with them.
2. This service might still collect network traffic data for pages where the service is installed, even when Users do not use it.
3. Vidergy Advertising (Vidergy Advertising LLC)
  1. Vidergy Advertising is an advertising service provided by Vidergy Advertising LLC that allows this Network Connected Service to incorporate content of this kind on its pages or in the User’s browser.
4. Personal Data processed:
  1. Trackers;
  2. Universally Unique Identifier (UUID);
  3. Usage Data; and
  4. Various types of Data as specified in this Policy and/or the privacy policy of the service.
  5. Place of Processing: U.S.A.

1. Opt-out:
  1. Contact Us at the contact information provided in this Policy; and
  2. Cease all use of this Network Connected Service.
2. Category of personal information collected according to the CCPA:
  1. internet information.
3. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.

Displaying Content From External Platforms – Gravatar (Automattic Inc.)
1. Gravatar is an image visualization service provided by Automattic Inc. that allows this Network Connected Service to incorporate content of this kind on its pages.
2. If Gravatar images are used accept input from a User, for example a comment form, the User’s email address or parts of it and any other information, including Data, submitted may be sent to Gravatar even if the User has not signed up for that service.
3. Gravatar (Automattic Inc.)
4. Personal Data processed:
  1. Usage Data; and
  2. Various types of Data as specified in this Policy and/or the privacy policy of the service.
5. Place of Processing:
  1. U.S.A.
  2. Gravatar Privacy Policy.
6. Category of personal information collected according to the CCPA:
  1. identifiers
  2. internet information.
7. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.
Displaying Content From External Platforms – YouTube Video Widget (Google LLC)
1. YouTube is a video content visualization service provided by Google LLC that allows this Network Connected Service to incorporate content of this kind on its pages.

1. This widget is set up in a way that ensures that YouTube won’t store information and cookies about Users on this Network Connected Service unless they play the video.
2. YouTube Video Widget (Privacy Enhanced Mode)(Google LLC)
  1. Google Fonts is a typeface visualization service provided by Google LLC that allows this Network Connected Service to incorporate content of this kind on its pages or in the User’s browser.
3. Personal Data processed:
  1. Trackers;
  2. Universally Unique Identifier (UUID); and
  3. Usage Data.
4. Place of Processing:
  1. U.S.A.
  2. YouTube (Google) Privacy Policy.
5. Category of personal information collected according to the CCPA:
  1. identifiers; and
  2. internet information.
6. This processing constitutes:
  1. a sale according to the CCPA; and
  2. a sale according to the VCDPA.

Tag Management – Google
1. This type of service helps Us and Our Data Processors to manage the tags or scripts needed on this Network Connected Service in a centralized fashion.
2. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
3. Google Tag Manager (Google LLC)
  1. Google Tag Manager is a tag management service provided by Google LLC that allows this Network Connected Service to have an improved when accessing network data such as web pages in the User’s browser.
4. Personal Data processed:
  1. Usage Data.
5. Place of Processing:
  1. U.S.A.
  2. Google Privacy Policy.
6. Category of personal information collected according to the CCPA:
  1. internet information.
7. This processing constitutes:
  1. a sale according to the CCPA

The rights of Users.
1. Users may exercise certain rights regarding their Data processed by Us and Our Data Processors.
2. In particular, Users have the right to:
  1. Withdraw consent at any time.
    1. A User has the right to withdraw consent where the User has previously given consent to the processing of their Personal Data.
  2. Object to processing of their Data.
    1. A User has the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent.
    2. Further details are provided in this section below.
  3. Access their Data.
    1. A User has the right to:
      - Learn if Data is being processed by Us or Our Data Processor;
      - Obtain disclosure regarding certain aspects of the processing; and
      - Obtain a copy of the Data undergoing processing
  4. Verify and seek rectification.
    1. A User has the right to:
      - Verify the accuracy of their Data; and
      - Ask for their Data to be updated or corrected.
  5. Restrict the processing of their Data.
    1. A User has the right, under certain circumstances, to restrict the processing of their Data.
    2. In this case, We or our Data Processors will not process the User’s Data for any purpose other than storing it.
  6. Have their Personal Data deleted or otherwise removed.
    1. A User has the right, under certain circumstances, to obtain the erasure of their Data from Us or Our Data Processors.
  7. Receive their Data and have it transferred to another controller.
    1. A User has the right to receive their Data in a structured, commonly used and machine readable format; and
    2. A User has the right, if technically feasible, to have their Data transmitted to another Person without any hindrance.
    3. This provision is applicable provided that the User’s Data is processed by automated means and that the processing is based on:
      - The User’s consent;
      - A contract which the User is part of; or
      - Pre-contractual obligations thereof.

1. Lodge a complaint.
  1. A User has the right to bring a claim before their competent data protection authority.

Details about the right to object to processing.
1. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Us or Our Data Processor or for the purposes of the legitimate interests pursued by Us or Our Data Processor, A User may object to such processing by providing a ground related to their particular situation to justify the objection.
2. The User must know, however, that should their Personal Data be processed for direct marketing purposes, the User can object to that processing at any time without providing any justification.
3. To learn, whether We or Our Data Processor is processing Personal Data for direct marketing purposes, the User may refer to the relevant section or sections of this Policy.
How to exercise these rights
1. Any requests to exercise User rights can be directed to Us through the contact details provided in this document.
2. Any requests to exercise User rights can be exercised free of charge.
3. We will address any request to exercise User rights as early as possible and always within six (6) months.

Cookie Policy.
1. This Section XI “Cookie Policy” informs Users about technologies that this Network Connected Service employes to achieve its purposes.
  1. Cookies and Cookie-type technologies allow Us and Our Data Processors to access and store information or use resources (e.g., by running a script) on the User’s smart device as the User interacts with this Network Connected Service.
2. For simplicity, all such Cookies and Cookie-type technologies may be referred to herein as Trackers within this Section XI “Cookie Policy” unless there is a reason to differentiate.
  1. Cookies can be used on both web and mobile browsers
  2. Cookies in the context of mobile apps are a browser-based Tracker.
  3. Within this Section XI “Cookie Policy”, the term Cookies is only used where it is specifically meant to indicate a browser-based Tracker.
3. Some of the purposes for which Trackers are used may require consent of the User.
4. Whenever a User grants consent, the User can freely withdraw consent at any time following the instructions provided herein.
5. This Network Connected Service uses Trackers managed directly by the Us and Our Data Processors (so-called “first-party” Trackers).
6. This Network Connected Service uses Trackers that enable services provided by a third-party (so-called “third- party” Trackers).
  1. Unless otherwise specified herein, third-party providers may access the Trackers the third-party manages.
7. The validity and expiration periods of Cookies and other Trackers may vary.
  1. In some cases, the validity and expiration periods of Cookies and other Trackers may depend on the lifetime set by Us, Our Data Processor, or the relevant provider .

1. In some cases, the validity and expiration periods of Cookies and other Trackers may expire upon termination of the User’s browsing session.
2. In addition to what is specified herein, a User may find more precise and updated information regarding lifetime specification as well as any other relevant information, for example the presence of other Trackers, in the linked privacy policies of the respective third-party providers or by contacting Us

Activities strictly necessary for the operation of this Network Connected Service and delivery of the Service.
1. This Network Connected Service uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of services available on or through the Network Connected Service.
Other activities involving the use of Trackers
1. Experience enhancement.
  1. This Network Connected Service uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.
2. Displaying content from external platforms.
  1. This type of service allows a User to view content hosted on external platforms directly from the pages of this Network Connected Service and interact with them.
  2. This type of service might collect web traffic data for the pages where the service is installed, even when a User does not use it.
  3. See Section IX “Detailed information on the processing of Personal Data.”
Measurement
1. This Network Connected Service uses Trackers to measure traffic and analyze behavior if a User with the goal of improving the operations of the Network Connected Service.
2. Analytics.
  1. The services measured herein enable Us and Our Data Processors to monitor and analyze web traffic.
  2. The services measured herein can be used to keep track of the behavior of a User.
  3. See Section IX “Detailed information on the processing of Personal Data.”
How to manage preferences and provide or withdraw consent
1. There are various ways for a User of this Network Connected Service to manage Tracker related preferences and to provide and withdraw consent, where relevant:.
  1. A User can manage preferences related to Trackers from directly within their own smart device.
  2. One way a User can manage preferences related to Trackers is to change the settings of a browser running on their smart device, for example, by preventing the use or storage of Trackers.
  3. When the use of Trackers is based on consent, a User can provide or withdraw such consent by setting their preferences within a cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
  4. A User may, via a relevant browser or device feature, delete previously stored Trackers, including those used to remember the User’s initial consent.
  5. A User may clear Trackers in the User’s browser’s local memory by deleting the browsing history.

With regard to third-party Trackers, a User can manage preferences and withdraw consent via:
- The related opt-out link (where provided);
- By using the means indicated in the third-party’s privacy policy; or
- By contacting the third-party.

Locating Tracker Settings
1. A User can find information relating to the management of Cookies in many commonly used browser:
2. A User may manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, for example, the device advertising settings on the mobile device.
3. A User may adjust tracking settings in general by opening a device settings menu on a smart device and adjusting the relevant settings.
Consequences of denying consent
1. A User is free to decide whether or not to grant consent.
  1. Note that Trackers help this Network Connected Service provide a better experience and advanced functionalities.
  2. In the absence of a User’s consent, We and Our Data Processors may be unable to provide related features.
Since the use of third-party Trackers through this Network Connected Service cannot be fully controlled by Us or Our Data Processors, any specific references to third-party Trackers are to be considered indicative.
To obtain more information, a User should consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, a User is encouraged to request from Us any further information on the use of such technologies by this Network Connected Service.

XII. Additional information about Data collection and processing.

Legal action.
1. A User’s Personal Data may be used for legal purposes by Us and Our Data Processors in any court of competent jurisdiction or in the stages leading to possible legal action arising from improper use of this Network Connected Service or the related services.
2. As a User. You are aware and You agree that We and Our Data Processors may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data

2.1 In addition to the information contained in this Policy, a User may, upon request, be provided with additional and contextual information concerning particular services or the collection and processing of Personal Data by this Network Connected Service.

System logs and maintenance
1. For operation and maintenance purposes, this Network Connected Service and any third-party services may collect files that record interaction with this Network Connected Service (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this Policy
1. A User may request more details concerning the collection or processing of Personal Data from Us at any time using the contact information We provide in this Policy.
How “Do Not Track” requests are handled
1. This Network Connected Service does not support “Do Not Track” requests.
2. A User should consult the privacy policy of each third-party service to understand whether or not such third-party services honor “Do Not Track” requests.

Changes to this Policy
1. We reserve the right to make changes to this Policy at any time.
2. If We make changes to this Policy, We will notify Users on this page and possibly within this Network Connected Service.
3. If We make changes to this Policy, We may send a notice to Users via any contact information available to Us.
4. Users are strongly recommended to check this page often, referring to the date of last modification listed herein.
5. Should changes We make affect processing activities performed on the basis of a User’s consent, We or our Data Processors shall collect new consent from the User, where required.

Change Date:	Reason/Disposition
June 10, 2023	Original

XIII. Information for Users in Brazil.

This section of the Policy is for Users in Brazil (“Brazilian User”).
This section of the Policy integrates with and supplements the information contained in the earlier sections of the Policy. The provisions contained in this section apply to Brazilian Users who reside in Brazil and Brazilian Users who access the Network Connected Service from Brazil, according to the Lei Geral de Proteção de Dados (“LGPD”). For such Brazilian Users, the provisions of this section supersede other and possibly divergent or conflicting provisions of this Policy.
A link to the LGPD is here: https://www.planalto.gov.br/ccivil_03/_ato2015-2018/2018/lei/l13709.htm
This section of the Policy adopts the definition for “Personal Information“ from the LGPD.
We will only process a Brazilian User’s Personal Information if We have a legal basis for such processing. Legal bases are as follows:
1. The Brazilian User’s consent to the relevant processing activities;
2. Compliance with a legal or regulatory obligation that lies with Us;
3. We are carrying out a public policy provided in laws or regulations or based on contracts, agreements and similar legal instruments;
4. A research entity is conducting a study, preferably on anonymized Personal Information;
5. The processing fulfills a contract and/or its preliminary procedures where the Brazilian User is a contract party;
6. We are exercising of Our rights in a judicial, administrative, or arbitration procedure;
7. We protecting the physical safety of the Brazilian User or a third party;
8. The processing protects the health of the Brazilian User or third party in a procedure carried out by a health entity or professional;
9. We are protecting our legitimate interests, provided that the Brazilian User’s fundamental rights and liberties do not prevail over Our interests; and
10. We are protecting the Brazilian User’s or Our credit..
To find out more about the legal bases of Our processing, the Brazilian User can contact Us at any time.
We process the categories of the Brazilian User’s Personal Information set forth in Section IX “Detailed information on the processing of Personal Data.”
The reason We process the Brazilian User’s Personal Information is set forth in Section VIII “The purposes of processing” and Section IX “Detailed information on the processing of Personal Data.”
The Brazilian User has the right to:
1. Obtain confirmation of the existence of processing activities on the Brazilian User’s Personal Information;
2. Access the Brazilian User’s Personal Information;
3. Have incomplete, inaccurate or outdated Personal Information rectified;
4. Obtain the anonymization, blocking, or elimination of the Brazilian User’s unnecessary or excessive Personal Information, or of information that is not being processed in compliance with the LGPD;
5. Obtain information on the possibility to provide or deny the Brazilian User’s consent and the consequences thereof;

1. Obtain information about the third parties with whom We share the Brazilian User’s Personal Information;
2. Obtain, upon the Brazilian User’s express request, the portability of the Brazilian User’s Personal Information (except for anonymized information) to another service or product provider, provided that Our commercial and industrial secrets are safeguarded;
3. Obtain the deletion of the Brazilian User’s Personal Information being processed if the processing was based upon the Brazilian User’s consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
4. Revoke the Brazilian User’s consent at any time;
5. Lodge a complaint related to the Brazilian User’s Personal Information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
6. Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
7. Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
8. Request the review of decisions made solely on the basis of the automated processing of the Brazilian User’s Personal Information, which affect the Brazilian User’s interests. These include decisions to define the Brazilian User’s personal, professional, consumer and credit profile, or aspects of the Brazilian User’s personality.
9. The Brazilian User will never be discriminated against, or otherwise suffer any sort of detriment, if the Brazilian User exercise the Brazilian User’s rights.
10. The Brazilian User can file the Brazilian User’s express request to exercise the Brazilian User’s rights free from any charge, at any time, by using the contact details provided in this Policy or via the Brazilian User’s legal representative.
11. We will strive to promptly respond to the Brazilian User’s requests. In any case, should it be impossible for Us to do so, We will make sure to communicate to the Brazilian User the factual or legal reasons that prevent Us from immediately, or otherwise ever, complying with the Brazilian User’s requests. In cases where We are not processing the Brazilian User’s Personal Information, We will indicate to the Brazilian User the physical or legal person to whom the Brazilian User should address the Brazilian User’s requests, if We are in the position to do so.
12. In the event that the Brazilian User files an access or Personal Information processing confirmation request, the Brazilian User should make sure that the Brazilian User specifies whether the Brazilian User would like the Brazilian User’s Personal Information to be delivered in electronic or printed form. The Brazilian User will also need to let Us know whether the Brazilian User wants Us to answer the Brazilian User’s request immediately, in which case We will answer in a simplified fashion, or if the Brazilian User needs a complete disclosure instead. In the latter case, We will respond within fifteen (15) days from the time of the Brazilian User’s request, providing the Brazilian User with all the information on the origin of the Brazilian User’s Personal Information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding Our commercial and industrial secrets.
13. In the event that the Brazilian User files a rectification, deletion, anonymization, or Personal Information blocking request, We will make sure to immediately communicate the Brazilian User’s request to other parties with whom We have shared the Brazilian User’s Personal Information in order to enable such third parties to also comply with the Brazilian User’s request – except in cases where such communication is proven impossible or involves disproportionate effort on Our side.
14. We are allowed to transfer the Brazilian User’s Personal Information outside of the Brazilian territory in the following cases:
15. When the transfer is necessary for international legal cooperation between public intelligence,investigation, and prosecution bodies, according to the legal means provided by the international law;
  1. When the transfer is necessary to protect the Brazilian User’s life or physical security or those of a third party;
  2. When the transfer is authorized by the ANPD;
  3. When the transfer results from a commitment undertaken in an international cooperation agreement;
  4. When the transfer is necessary for the execution of a public policy or legal attribution of public service;
  5. When the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

XIV. Information for Users in Europe.

This section of the Policy is for Users in Europe (“European User”).
This section of the Policy integrates with and supplements the information contained in the earlier sections of the Policy. The provisions contained in this section apply to European Users who reside in Europe and European Users who access the Network Connected Service from Europe, according to the GDPR. For such European Users, the provisions of this section supersede other and possibly divergent or conflicting provisions of this Policy.
For the avoidance of doubt, this Policy has been prepared based on provisions of multiple legislations and multiple jurisdictions, including Art. 13/14 of Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”). This Policy relates solely to this Network Connected Service if not stated otherwise within this Policy.
A link to the GDPR is here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

XV. Information for Users in the State of California, U.S.A.

This section of the Policy is for Users in California, U.S.A. (“Californian User”)
This section of the Policy integrates with and supplements the information contained in the earlier sections of the Policy. The provisions contained in this section apply to Californian Users who reside in the state of California, U.S.A. and Californian Users who access the Network Connected Service from the state of California, U.S.A., according to the California Consumer Privacy Act of 2018 (“CCPA”), as updated by the California Privacy Rights Act (“CPRA”) and subsequent regulations. For such Californian Users, the provisions of this section supersede other and possibly divergent or conflicting provisions of this Policy.
A link to the CCPA is here: https://www.oag.ca.gov/privacy/ccpa
A link to the CPRA is here: https://cppa.ca.gov/regulations/consumer_privacy_act.html
This section of the Policy adopts the definition for “Personal Information” as defined in the CCPA/CPRA.
We process the categories of the Californian User’s Personal Information set forth in Section IX “Detailed information on the processing of Personal Data.”
The reason We process the Californian User’s Personal Information is set forth in Section VIII “The purposes of processing” and Section IX “Detailed information on the processing of Personal Data.”
We collect the following categories of Personal Information: identifiers and internet information.
We do not collect sensitive data.
We will not collect additional categories of Personal Data without notifying the Californian User.
We may use the Californian User’s Personal Information to allow the operational functioning of this Network Connected Service and features thereof (“business purposes”). In such cases, the Californian User’s 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 the Californian User’s Personal Information for other reasons such as for commercial purposes (as indicated within Section IX “Detailed information on the processing of Personal Data.”), 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 the Californian User’s Personal Information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without the Californian User’s consent.
Unless stated otherwise inside Section IX “Detailed information on the processing of Personal Data,” We will not retain the Californian User’s Personal Information for longer than is reasonably necessary for the purpose(s) such data has been collected for.
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from Californian Users when Californian Users use this Network Connected Service.
For example, Californian Users directly provide Personal Information when the Californian Users submit requests via any forms on this Network Connected Service. Californian Users also provide Personal Information indirectly when the Californian Users navigate this Network Connected Service, as Personal Information about the Californian User is automatically observed and collected.
Finally, We may collect the Californian User’s Personal Information from third parties that work with us in connection with the service or with the functioning of this Application and features thereof.
We may collect, use, and/or disclose the Californian User’s Personal Information to 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 share the Californian User’s Personal Information with the third parties listed in detail in Section IX “Detailed information on the processing of Personal Data.” 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 who is not any of the following: a service provider or a contractor, as defined by the CCPA.
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 or Network Connected Service runs ads, or facilitates the running of 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.
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 Californian Users’ Personal Information.
We sell or share Californian Users’ Personal Information with the third parties listed in detail in Section IX “Detailed information on the processing of Personal Data.” These third parties are grouped and categorized in accordance with the different purposes of processing.
The Californian User has the right to opt out of the sale of the Californian User’s Personal Information. This means that whenever the Californian User requests Us to stop selling or sharing the Californian User’s data, We will abide by the Californian User’s request without requiring any verifiable request.
To fully exercise the Californian User’s right to opt out the Californian User can contact Us at any time.
We use Personal Information collected from the Californian User in connection with the submission of the Californian User’s opt-out request solely for the purpose of complying with the request.
WE MAY PROCESS THE CALIFORNIAN USER’S PERSONAL INFORMATION FOR TARGETED ADVERTISING. THIS IS THE CALIFORNIAN USER’S NOTICE THAT WE WILL GRANT THE CALIFORNIAN USER’S RIGHT TO OPT OUT OF THE PROCESSING OF THE CALIFORNIAN USER’S PERSONAL INFORMATION FOR TARGETED ADVERTISING IF SUCH RIGHT IS REQUESTED.
For a simplified opt-out method Californian Users can also use the privacy choices link if We elect to provide such a link on this Network Connected Service.
If Californian Users 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”), Californian Users 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 of the Californian Users, which acts as a mechanism that our Network Connected Service can use to indicate the Network Connected Service supports the GPC signal. If Californian User want to use GPC, Californian Users can download and enable the GPC signal via a participating browser or browser extension. More information about downloading GPC is available here.
We use Personal Information collected from Californian Users in connection with the submission of Californian Users’ opt-out request solely for the purposes of complying with the opt-out request.
Once the Californian User has opted out, We are required to wait at least 12 months before asking whether the Californian User has had a change of mind.
Californian Users have privacy rights under the California Consumer Privacy Act.
Californian Users may exercise certain rights regarding the Californian User’s data processed by Us. In particular, Californian Users have the right to request that we disclose to you:
1. The categories of Personal Information that We collect about the Californian User;
2. The sources from which the Personal Information is collected;
3. The purposes for which We use the Californian User’s information;
4. To whom We disclose such information;
5. The specific pieces of Personal Information We have collected about the Californian User.
Californian Users also have the right to know what Personal Information is sold or shared and to whom. In particular, Californian Users have the right to request two separate lists from us where we disclose:
1. The categories of Personal Information that We sold or shared about the Californian User and the categories of third parties to whom the Personal Information was sold or shared;
2. The categories of Personal Information that We disclosed about the Californian User 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 Californian Users to transmit the information to another entity without hindrance – provided that this is technically feasible.
Californian Users have the right to request that We delete any of the Californian User’s 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 Network Connected Service, 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 the Californian User’s right, We will delete the Californian User’s 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.
Californian Users have the right to request that We correct any inaccurate Personal Information We maintain about the Californian Users, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
Californian Users have the right to opt out of the sale or sharing of the Californian User’s Personal Information. Californian Users also have the right to request that We limit Our use or disclosure of the Californian User’s sensitive Personal Information.
We will not discriminate against Californian Users for exercising the Californian User’s rights under the CCPA. This means that We will not discriminate against Californian Users, including, but not limited to, by denying goods or services, charging Californian Users a different price, or providing a different level or quality of goods or services just because the Californian User exercised the Californian User’s consumer privacy rights.
However, if Californian Users refuse to provide the Californian User’s Personal Information to Us or ask Us to delete or stop selling the Californian User’s Personal Information, and that Personal Information for sale is necessary for Us to provide the Californian User with goods or services, We may not be able to complete that transaction.
To the extent permitted by the law, We may offer Californian Users promotions, discounts, and other deals in exchange for collecting, keeping, or selling the Californian User’s Personal Information, provided that the financial incentive offered is reasonably related to the value of the Californian User’s Personal Information.
To exercise the rights described above, Californian Users need to submit a verifiable request to Us by contacting Us via the details provided in this Policy.
For Us to respond to the Californian User’s request, it’s necessary that We know who the Californian User is. Therefore, Californian Users can only exercise the above rights by making a verifiable request which must:
1. Provide sufficient information that allows Us to reasonably verify the Californian User is the person about whom We collected Personal Information or an authorized representative;
2. Describe the Californian User’s 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 the Californian User’s identity and therefore confirm the Personal Information in Our possession actually relates to the Californian User.
Making a verifiable consumer request does not require the Californian User to create an account with Us. We will use any Personal Information collected from Californian Users in connection with the verification of the Californian User’s 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 the Californian User cannot personally submit a verifiable request, the Californian User can authorize a person registered with the California Secretary of State to act on the Californian User’s behalf.
If the Californian User is an adult, the Californian User can make a verifiable request on behalf of a minor under the Californian User’s parental authority.
Californian Users can submit a maximum number of 2 requests over a period of 12 months.
We will confirm receipt of Californian Users’ verifiable requests within 10 days and provide information about how We will process the Californian User’s request.
We will respond to the Californian User’s request within 45 days of its receipt. Should We need more time, We will explain to the Californian User the reasons why, and how much more time We need. In this regard, We may take up to 90 days to fulfill the Californian User’s request.
Our disclosure(s) will cover the preceding 12-month period. Only with regard to Personal Information collected on or after January 1, 2022, Californian Users have the right to request that We disclose information beyond the 12-month period, and We will provide them to the Californian User unless doing so proves impossible or would involve a disproportionate effort.
Should We deny the Californian User’s request, We will explain the reasons behind our denial.
We do not charge a fee to process or respond to a Californian User’s 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.

XVI. Information for Users in the State of Colorado, U.S.A.

This section of the Policy is for Users in the state of Colorado, U.S.A. (“Coloradan User”)
This section of the Policy integrates with and supplements the information contained in the earlier sections of the Policy. The provisions contained in this section apply to Coloradan Users who reside in the state of Colorado, U.S.A. and Coloradan Users who access the Network Connected Service from the state of Colorado, U.S.A., according to the Colorado Privacy Act (“CPA”). For such Coloradan Users, the provisions of this section supersede other and possibly divergent or conflicting provisions of this Policy.
A link to the CPA is here: https://leg.colorado.gov/sites/default/files/documents/2021A/bills/2021a_190_enr.pdf
This section of the Policy adopts the definition for “Personal Data” as defined in the CPA.
We process the categories of the Coloradan User’s Personal Data set forth in Section IX “Detailed information on the processing of Personal Data.”
The reason We process the Coloradan User’s Personal Data is set forth in Section VIII “The purposes of processing” and Section IX “Detailed information on the processing of Personal Data.”
We collect 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 the Coloradan User.
We won’t process the Coloradan User’s information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without the Coloradan User’s consent. The Coloradan User can freely give, deny, or withdraw such consent at any time.
We share the Coloradan User’s Personal Data with the third parties listed in detail in Section IX “Detailed information on the processing of Personal Data.” 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.
For Our purposes, the words “sale” “sell” or “sold” mean any “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. As specified in Section IX “Detailed information on the processing of Personal Data,” our use of the Coloradan User’s Personal Data may be considered a sale under CPA.
The Coloradan User has the right to opt out of the sale of the Coloradan User’s Personal Data. This means that whenever the Coloradan User requests Us to stop selling the Coloradan User’s data, We will abide by the Coloradan User’s request. To fully exercise the Coloradan User’s right to opt out the Coloradan User can contact Us at any time.
We use Personal Data collected from the Coloradan User in connection with the submission of the Coloradan User’s opt-out request solely for the purpose of complying with the request.
WE MAY PROCESS THE COLORADAN USER’S PERSONAL DATA FOR TARGETED ADVERTISING. THIS IS THE COLORADAN USER’S NOTICE THAT WE WILL GRANT THE COLORADAN USER’S RIGHT TO OPT OUT OF THE PROCESSING OF THE COLORADAN USER’S PERSONAL DATA FOR TARGETED ADVERTISING IF SUCH RIGHT IS REQUESTED IN WRITING.
We do not use Personal Data for purposes of profiling that presents a reasonably foreseeable risk of: (i) unfair or deceptive treatment of, or unlawful disparate impact on, consumers; (ii) financial or physical injury to consumers;

(iii) a physical or other intrusion upon the solitude or seclusion, or the private affairs or concerns, of consumers if the intrusion would be offensive to a reasonable person; or (iv) other substantial injury to consumers.

Coloradan Users have privacy rights under the Colorado Privacy Act.
Coloradan Users may exercise certain rights regarding the Coloradan User’s data processed by Us. In particular, Coloradan Users have the right to do the following:
1. Access Personal Data: the right to know. Coloradan Users have the right to request that We confirm whether or not We are processing the Coloradan User’s Personal Data. Coloradan Users also have the right to access such Personal Data.
2. Correct inaccurate Personal Data. Coloradan Users have the right to request that We correct any inaccurate Personal Data We maintain about the Coloradan User, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
3. Request the deletion of the Coloradan User’s Personal Data. Coloradan Users have the right to request that We delete any of the Coloradan User’s Personal Data.
4. Obtain a copy of the Coloradan User’s Personal Data. We will provide the Coloradan User’s Personal Data in a portable and usable format that allows the Coloradan User to transfer data easily to another entity

– provided that this is technically feasible.

1. Opt out of the processing of the Coloradan User’s 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 the Coloradan User.
2. Non-discrimination. We will not discriminate against Coloradan Users for exercising the Coloradan User’s rights under the CPA. This means that We will not, among other things, deny goods or services, charge Coloradan Users a different price, or provide a different level or quality of goods or services just because the Coloradan User exercised the Coloradan User’s consumer privacy rights. However, if the Coloradan User refuses to provide the Coloradan User’s Personal Data to Us or ask Us to delete or stop selling the Coloradan User’s Personal Data, and that Personal Data or sale is necessary for Us to provide the Coloradan User 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 Coloradan Users, including offering goods or services for no fee, if the Coloradan Users have exercised the Coloradan Users’ right to opt out, or Our offer is related to the Coloradan User’s voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.
3. To exercise the rights described above, Coloradan Users or their authorized third party, including via browser/device signals, need to submit a request to us.
4. For Us to respond to a Coloradan User’s request, we need to know who the Coloradan User is.
5. We will not respond to any request if We are unable to verify the Coloradan User’s identity using commercially reasonable efforts and therefore confirm that the Personal Data in Our possession actually relates to the Coloradan User. In such cases, We may request that the Coloradan User provide additional information which is reasonably necessary to authenticate the Coloradan User and the Coloradan User’s request.
6. Making a consumer request does not require Coloradan Users to create an account with Us. However, We may require Coloradan Users to use an existing account. We will use any Personal Data collected from a Coloradan User in connection with the Coloradan User’s 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.
7. If the Coloradan User is an adult, the Coloradan User can make a request on behalf of a minor under the Coloradan User’s parental authority.
8. We will respond to the Coloradan User’s 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 the Coloradan User 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.
9. Should We deny the Coloradan User’s request, We will explain to the Coloradan User 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 the Coloradan User’s right to appeal such decision by submitting a request to Us via the details provided in this

Policy. Within 60 days of receipt of the appeal, We will inform the Coloradan User 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 the Coloradan User may contact the Colorado Attorney General to submit a complaint.

26. We do not charge a fee to respond to the Coloradan User’s request, for up to two requests per year. If the Coloradan User 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.

XVII. Information for Users in Florida, U.S.A.

This section of the Policy is for Users in Florida, U.S.A. (“Floridian User”).
This section of the Policy will integrate with and supplement the information contained in the earlier sections of the Policy at some point in the future. The provisions contained in this section will apply to Floridian Users who reside in the state of Florida, U.S.A. and Floridian Users who access the Network Connected Service from the state of Florida, U.S.A., according to the “Florida Consumer Privacy Act” (“FCPA”) when such act is passed into law. For such Floridian Users, the provisions of this section will supersede other and possibly divergent or conflicting provisions of this Policy.

XVIII. Information for Users in the Commonwealth of Virginia, U.S.A.

This section of the Policy is for Users in Virginia, U.S.A. (“Virginian User”)
This section of the Policy integrates with and supplements the information contained in the earlier sections of the Policy. The provisions contained in this section apply to Virginian Users who reside in the Commonwealth of Virginia, U.S.A. and Virginian Users who access the Network Connected Service from the Commonwealth of Virginia, U.S.A., according to the Virginia Consumer Data Protection Act (“VCDPA”). For such Virginian Users, the provisions of this section supersede other and possibly divergent or conflicting provisions of this Policy.
A link to the VCDPA is here: https://law.lis.virginia.gov/vacode/title59.1/chapter53/
This section of the Policy adopts the definition for “Personal Data” as defined in the VCDPA.
We process the categories of the Virginian User’s Personal Data set forth in Section IX “Detailed information on the processing of Personal Data.”
The reason We process the Virginian User’s Personal Data is set forth in Section VIII “The purposes of processing” and Section IX “Detailed information on the processing of Personal Data.”
We collect 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 the Virginian User.
We won’t process the Virginian User’s information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without the Virginian User’s consent. The Virginian User can freely give, deny, or withdraw such consent at any time.
We share the Virginian User’s Personal Data with the third parties listed in detail in Section IX “Detailed information on the processing of Personal Data.” 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.
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 Section IX “Detailed information on the processing of Personal Data,” our use of the Virginian User’s Personal Data may be considered a sale under VCDPA.
The Virginian User has the right to opt out of the sale of the Virginian User’s Personal Data. This means that whenever the Virginian User requests Us to stop selling the Virginian User’s data, We will abide by the Virginian User’s request. To fully exercise the Virginian User’s right to opt out the Virginian User can contact Us at any time.
We use Personal Data collected from the Virginian User in connection with the submission of the Virginian User’s opt-out request solely for the purpose of complying with the request.
WE MAY PROCESS THE VIRGINIAN USER’S PERSONAL DATA FOR TARGETED ADVERTISING. THIS IS THE VIRGINIAN USER’S NOTICE THAT WE WILL GRANT THE VIRGINIAN USER’S RIGHT TO OPT OUT OF THE PROCESSING OF THE VIRGINIAN USER’S PERSONAL DATA FOR TARGETED ADVERTISING IF SUCH RIGHT IS REQUESTED IN WRITING.
Virginian Users have privacy rights under the Virginia Consumer Data Protection Act.
Virginian Users may exercise certain rights regarding the Virginian User’s data processed by Us. In particular, Virginian Users have the right to do the following:
1. Access Personal Data: the right to know. Virginian Users have the right to request that We confirm whether or not We are processing the Virginian User’s Personal Data. Virginian Users also have the right to access such Personal Data.

1. Correct inaccurate Personal Data. Virginian Users have the right to request that We correct any inaccurate Personal Data We maintain about the Virginian User, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
2. Request the deletion of the Virginian User’s Personal Data. Virginian Users have the right to request that We delete any of the Virginian User’s Personal Data.
3. Obtain a copy of the Virginian User’s Personal Data. We will provide the Virginian User’s Personal Data in a portable and usable format that allows the Virginian User to transfer data easily to another entity– provided that this is technically feasible.

1. Opt out of the processing of the Virginian User’s 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 the Virginian User.
2. Non-discrimination. We will not discriminate against Virginian Users for exercising the Virginian User’s rights under the VCDPA. This means that We will not, among other things, deny goods or services, charge Virginian Users a different price, or provide a different level or quality of goods or services just because the Virginian User exercised the Virginian User’s consumer privacy rights. However, if the Virginian User refuses to provide the Virginian User’s Personal Data to Us or ask Us to delete or stop selling the Virginian User’s Personal Data, and that Personal Data or sale is necessary for Us to provide the Virginian User 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 Virginian Users, including offering goods or services for no fee, if the Virginian Users have exercised the Virginian Users’ right to opt out, or Our offer is related to the Virginian User’s voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

To exercise the rights described above, Virginian Users need to submit a request to us.
For Us to respond to a Virginian User’s request, we need to know who the Virginian User is.
We will not respond to any request if We are unable to verify the Virginian User’s identity using commercially reasonable efforts and therefore confirm that the Personal Data in Our possession actually relates to the Virginian User. In such cases, We may request that the Virginian User provide additional information which is reasonably necessary to authenticate the Virginian User and the Virginian User’s request.
Making a consumer request does not require Virginian Users to create an account with Us. However, We may require Virginian Users to use an existing account. We will use any Personal Data collected from a Virginian User in connection with the Virginian User’s 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 the Virginian User is an adult, the Virginian User can make a request on behalf of a minor under the Virginian User’s parental authority.
We will respond to the Virginian User’s 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 the Virginian User 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 the Virginian User’s request, We will explain to the Virginian User 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 the Virginian User’s right to appeal such decision by submitting a request to Us via the details provided in this Policy. Within 60 days of receipt of the appeal, We will inform the Virginian User 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 the Virginian User may contact the Virginia Attorney General to submit a complaint.
We do not charge a fee to respond to the Virginian User’s request, for up to two requests per year. If the Virginian User 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.

XIX. Information for Users in Washington, U.S.A.

This section of the Policy is for Users in Washington, U.S.A. (“Washingtonian User”)
This section of the Policy will integrate with and supplement the information contained in the earlier sections of the Policy at some point in the future. The provisions contained in this section will apply to Washingtonian Users who reside in the state of Washington, U.S.A. and Washingtonian Users who access the Network Connected Service from the state of Washington, U.S.A., according to the “Washington Privacy Act” (“WPA”) when such act is passed into law. For such Washingtonian Users, the provisions of this section will supersede other and possibly divergent or conflicting provisions of this Policy.