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Privacy Policy

We take the protection of our website users’ data very seriously and are committed to protecting the information users provide to us in connection with their use of our website. We are further committed to protecting and using your data in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use and disclosure of your data when you access the services through your devices using our digital assets.

Please read this Privacy Policy carefully and make sure you fully understand our practices regarding your data before you use our services. If you have read and fully understood this policy and do not agree with our practices, you must stop using our digital assets and services. By using our services, you acknowledge the terms of this Privacy Policy. Continued use of the services constitutes your consent to this Privacy Policy and any amendments to it.

What data do we collect?

Below is an overview of the data we may collect:

  • Non-identified and non-identifiable information that you provide during the registration process or that is collected through your use of our services (“non-personal data”). Non-personal data does not allow conclusions to be drawn about who it was collected from. The non-personal data we collect consists mainly of technical and aggregated usage information.

  • Individually identifiable information, i.e. any information that identifies you or could reasonably be used to identify you (“personal data”). The personal data we collect through our services may include information requested from time to time, such as names, email addresses, postal addresses, phone numbers, IP addresses and more. When we combine personal data with non-personal data, we treat the combined data as personal data for as long as it remains combined.

How do we collect data?

The main methods we use to collect data are:

  • We collect data when you use our services. When you visit our digital assets and use our services, we may collect, record and store usage, sessions and related information.

  • We collect data that you provide to us yourself, for example when you contact us directly through a communication channel (e.g. an email with a comment or feedback).

  • We may collect data from third-party sources, as described below.

  • We collect data that you provide to us when you log in to our services through a third-party provider such as Facebook or Google.

Why do we collect this data?

We may use your data for the following purposes:

  • to provide and operate our services;

  • to develop, customize and improve our services;

  • to respond to your feedback, inquiries and requests and to offer assistance;

  • to analyze demand and usage patterns;

  • for other internal, statistical and research purposes;

  • to improve our data security and fraud prevention capabilities;

  • to investigate violations, enforce our terms and policies, and comply with applicable law, regulations or governmental orders;

  • to send you updates, news, promotional material and other information related to our services. For promotional emails, you can decide for yourself whether you wish to keep receiving them. If not, simply click the unsubscribe link in those emails.

Who do we share this data with?

We may share your data with our service providers in order to operate our services (e.g. storing data via third-party hosting services, providing technical support, etc.).

We may also disclose your data in the following circumstances: (i) to investigate, detect, prevent or take action against unlawful activity or other misconduct; (ii) to establish or exercise our rights of defense; (iii) to protect our rights, property or personal safety, or the safety of our users or the public; (iv) in the event of a change of control of us or of one of our affiliates (by way of merger, acquisition or purchase of (substantially) all assets, among others); (v) to collect, hold and/or manage your data through authorized third-party providers (e.g. cloud service providers) as appropriate for business purposes; (vi) to work with third-party providers to improve your user experience. For the avoidance of doubt, we may transfer, share or otherwise use non-personal data with third parties at our own discretion.

When you visit or access our services, we authorize third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services (“tracking technologies”). These tracking technologies may allow third parties to collect your data automatically in order to improve the navigation experience on our digital assets, optimize their performance and provide a tailored user experience, as well as for security and fraud prevention purposes.

To learn more, please read our Cookie Policy.

We will not share your email address or other personal data with advertising companies or advertising networks without your consent.

Where do we store the data?

Please note that our companies, as well as our trusted partners and service providers, are located around the world. For the purposes described in this Privacy Policy, we store and process all non-personal data we collect in different jurisdictions.

How long is the data retained?

Please note that we retain the data we collect for as long as necessary to provide our services, to comply with our legal and contractual obligations towards you, to resolve disputes and to enforce our agreements.

We may correct, supplement or delete inaccurate or incomplete data at any time at our own discretion.

How do we protect the data?

The hosting service for our digital assets provides us with the online platform through which we offer you our services. Your data may be stored through our hosting provider’s data storage, databases and general applications. It stores your data on secure servers behind a firewall and offers secure HTTPS access to most areas of its services.

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee the absolute protection and security of any data you upload, publish or otherwise share with us or others.

For this reason, we ask you to set strong passwords and, where possible, not to send us or others any confidential information whose disclosure you believe could cause you substantial or lasting harm. Since email and instant messaging are not considered secure forms of communication, we also ask you not to share any confidential information through either of these channels.

How do we deal with minors?

The services are not intended for users who have not yet reached the age of majority. We will not knowingly collect data from children. If you are not yet of legal age, you should not download or use the services or provide us with any information.

We reserve the right to request proof of age at any time so that we can verify whether minors are using our services. If we become aware that a minor is using our services, we may prohibit and block that user’s access to our services and may delete any data about that user stored with us. If you have reason to believe that a minor has shared data with us, please contact us as explained below.

We use your personal data only for the purposes set out in this Privacy Policy and only if we are satisfied that:

  • the use of your personal data is necessary to perform or enter into a contract (e.g. to provide you with the services themselves or with customer care or technical support);

  • the use of your personal data is necessary to comply with relevant legal or regulatory obligations; or

  • the use of your personal data is necessary to support our legitimate business interests (provided that this is done at all times in a manner that is proportionate and respects your privacy rights).

As an EU resident, you may:

  • request confirmation as to whether or not personal data concerning you is being processed, and request access to your stored personal data and certain additional information;

  • request to receive the personal data you have provided to us in a structured, commonly used and machine-readable format;

  • request the correction of your personal data held by us;

  • request the deletion of your personal data;

  • object to our processing of your personal data;

  • request the restriction of the processing of your personal data; or

  • file a complaint with a supervisory authority.

Please note, however, that these rights are not unlimited and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data we collect and how we use it, please contact us as indicated below.

In the course of providing the services, we may transfer data across borders to affiliates or other third parties, and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection for personal data exists. We will take appropriate steps to ensure that we have adequate contractual arrangements in place with our third parties, so that appropriate safeguards are in place to minimize the risk of unlawful use, alteration, deletion, loss or theft of your personal data, and that these third parties act in accordance with applicable laws at all times.

Updates or changes to this Privacy Policy

We may revise this Privacy Policy from time to time at our own discretion; the version published on the website is always the current one (see the “last updated” date). Please check this Privacy Policy regularly for changes. In the case of material changes, we will post a notice on our website. If you continue to use the services after being notified of changes on our website, this constitutes your acknowledgement of and consent to the changes to this Privacy Policy and your agreement to be bound by the terms of those changes.

Contact

If you have general questions about the services or about the data we collect about you and how we use it, please contact us via the contact form under “About”.

The information contained here does not constitute legal advice, and you should not rely on it alone. Specific requirements regarding legal terms and policies may differ from state to state and/or from jurisdiction to jurisdiction. As set out in our Terms of Use, you are responsible for ensuring that your services are permitted under, and comply with, the law applicable to you.

To ensure that you fully comply with your legal obligations, we strongly recommend that you seek professional advice to better understand which requirements apply to you specifically.

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